Purpose of the consultation
ICAEW is consulting on these proposed changes for transparency and to ensure that they are consistent with its duty to act in the public interest. Consulting also helps protect against any unforeseen or unintended consequences that may be brought about by the changes.
This consultation is likely to be of interest to ICAEW members, ICAEW member and regulated firms, non-members who are registered with ICAEW for a regulated activity, consumer groups and other professional services regulators.
ICAEW Chartered Accountants have established over many years a reputation for their individual integrity and expertise and their collective commitment to serve the public interest.
ICAEW’s current CPD programme is centred around the 'RAID' approach: Reflect, Act, Impact, Declare. This requires members to:
- reflect on their current role and learning needs;
- take appropriate action to address those needs;
- assess the impact of that action to ensure their needs have been met; and
- declare annually their CPD status for the previous year.
The CPD year runs in line with the billing of membership fees; in accordance with Principal Bye-law 56, by renewing their membership each year, members confirm that they are compliant with ICAEW’s CPD requirements.
Members must be able to provide ICAEW promptly on request with their CPD records. ICAEW provides templates to assist members with recording and members can record CPD on their online ICAEW account. Much learning and development support is available to members via ICAEW, for instance through the technical Faculties and the Academy of Professional Development.
Members can currently claim exemption from CPD if they do not provide any accountancy services (with or without reward), do not provide any other service for reward, do not act as a trustee or director of a body corporate (or other similar position), and have no intention of providing any of the above services in the future.
ICAEW’s current CPD programme has been in place since 2005; the move to an outputs-based model was progressive and one that other similar organisations subsequently adopted. However, times have changed and our CPD policy must be adapted to reflect the increasingly complex world which our members operate in. The proposed changes will provide members with greater clarity regarding the amount and type of CPD they should undertake.
There is also an increasing expectation on the part of ICAEW’s oversight regulators that professional bodies should be expecting to see more tangible evidence that their members are keeping themselves up to date with developments in areas where they are asked to provide advice and assistance and that this evidence is more closely and regularly monitored with disciplinary consequences for those who do not comply.
Increased regulatory expectations and the audit reform agenda underscore the need for ICAEW to act to maintain and enhance public trust in the profession. ICAEW is therefore proposing to make changes to its CPD policy with the aim of improving and maintaining the professional, technical, and business excellence of ICAEW Chartered Accountants.
While we intend to retain RAID as the overarching guidance behind the new CPD policy, we are proposing to introduce:
- An annual mandatory ethics CPD requirement for all members.
- The introduction of risk-based CPD requirements based on the risk profile of a member’s area of work (particularly the level of risk to the public if there were unforeseen adverse consequences resulting from a member’s actions, omissions or advice).
- The requirement for a minimum number of verifiable CPD hours for each of the three Risk Categories.
We are proposing a phased introduction of this policy.
- The introduction of a mandatory ethics CPD requirement for all members.
- Members working in practice will continue to be subject to the overarching RAID principle but will also be required to complete the specified number of verifiable and non-verifiable CPD hours depending on the Risk Category they belong to.
- Members working in business will not be subject to the minimum number of verifiable hours requirement for this CPD year but will be obliged to continue to apply RAID and will be provided with enhanced guidance on how to apply RAID including guidance on the likely future Risk Categories for members in business.
- All members in practice and business (other than those who are exempted by the new policy) will be subject to the overarching RAID principle but will be required to complete the specified number of verifiable and non-verifiable CPD hours depending on the Risk Category they belong to. All members will also be required to comply within their verifiable hours with specified ethics learning outcomes.
New ethics learning requirement
Ethical behaviour is vital to ensure compliance with the accountancy profession’s commitment to the public interest.
It is proposed that all members would annually be required to undertake, declare, and evidence compliance with specified learning outcomes aligned to the ICAEW Code of Ethics. ICAEW will provide learning resources for all members from the implementation date of the new policy. Members will not be required to undertake the ICAEW programme of learning but must be able to provide verifiable evidence if they choose to use an alternative programme.
The ICAEW ethics learning programmes is expected to comprise four hours of CPD (year one). Subsequent years will comprise approximately one hour of CPD annually. This requirement to undertake ethics will extend to non-ICAEW members registered with ICAEW as Responsible Individuals, Key Audit Partners, and insolvency practitioners.
Risk categories for members in practice
The proposed policy will require members to identify which Risk Category they belong to and then complete the minimum number of verifiable and non-verifiable CPD hours annually as prescribed for that Risk category as follows:
a) Risk Category 1 members will be required to complete a minimum 40 hours’ CPD of which 30 hours must be 'relevant and verifiable'.
b) Risk Category 2 members will be required to complete a minimum 30 hours’ CPD of which 20 hours must be 'relevant and verifiable'.
c) Risk Category 3 members will be required to complete a minimum 20 hours’ CPD of which 10 hours must be 'relevant and verifiable'.
We have set out below examples of areas of work which are currently proposed to be included within each Risk Category This list is not intended to be exhaustive and the final categorisation of work areas in the new policy will be determined by ICAEW Council after considering feedback from this consultation and will thereafter be kept under review.
Risk Category 1: 40 hours (of which minimum 30 must be verifiable)
a) CASS engagement leaders and ICAEW members involved in these audits.
b) Responsible individuals undertaking PIE audits and ICAEW members involved in these audits.
c) Key Audit Partners undertaking major local public audits and ICAEW members involved in these audits.
d) ICAEW members involved in audit regulation, monitoring, or enforcement within an oversight body or accountancy organisation.
e) Appointment-taking insolvency practitioners and ICAEW members involved in these engagements.
f) Members providing tax mitigation advice permitted under the Professional Conduct Relating to Taxation (PCRT).
g) Internal auditors engaged by PIEs.
Risk Category 2: 30 hours (of which minimum 20 must be verifiable)
a) Responsible individuals undertaking large corporate audits (as defined in the Companies Act 2006); pension scheme audits; charity audits and ICAEW members involved in these audits.
b) Key Audit Partners undertaking non-major local public audits and ICAEW members involved in these audits.
c) Members undertaking international corporate tax planning.
d) Members undertaking personal tax planning for high net-worth individuals.
e) Members acting as Forensic Accountants or Expert Witnesses.
f) Members working in corporate finance g) Members and non-members authorised for probate.
h) Members undertaking non-reserved legal services.
i) Members undertaking Designated Professional Body (Investment Business) licensed activities.
j) Members undertaking Designated Professional Body (Consumer Credit) licenced activities.
k) Internal auditors engaged by large corporate (as defined under the Companies Act 2006) entities.
l) Non-appointment taking insolvency practitioners.
Risk Category 3: 20 hours (of which minimum 10 must be verifiable)
a) Responsible individuals auditing smaller/other entities and ICAEW members involved in these audits.
b) Inactive responsible individuals holding audit registration for other purposes but not conducting audits.
c) Internal auditors engaged by smaller/other corporate entities.
d) All other ICAEW PC holders.
e) Members responsible for Solicitors Regulation Authority Accounts Rules reporting.
f) All other members working in practice.
International equivalent roles are also included; members will be expected to determine whether they fall into a risk category if holding an equivalent role outside the UK.
The new CPD policy will also make clear that, following the obligation which they already have through the ICAEW Code of Ethics, ICAEW member firms will be responsible under the new policy for ensuring that their employees are compliant with the new CPD policy. It is proposed that monitoring of compliance with the new CPD policy be carried out by QAD during visits by the checking and reviewing of training records.
Relevant and Verifiable CPD
Relevant and Verifiable CPD is defined as 'An activity that meets a specific learning outcome(s) identified as necessary to remain up to date and competent in the role(s) which can also be evidenced.'
Under the new policy, all CPD must continue to be relevant to a member’s role and address their learning needs. Relevant and Verifiable CPD includes any activity that meets a specific learning outcome(s) identified as necessary to remain up to date and competent in the role(s) which can be evidenced.
Evidence will encompass activities that extend beyond attendance on internal/external training courses and will include, for example:
- File notes of technical research.
- Meetings with experts on technical issues.
- Research notes into ethical issues.
- Presentations based on research.
- Passing exams or diplomas requiring self-directed learning.
- Writing technical articles.
- Participation in discussion groups (including District Society meetings).
- Registration/attendance at webinars.
- Participation in soft-skill training/courses.
Long-term leave and return to work
It is proposed that members on leave from their role throughout the whole CPD year will be exempt from the verified hours and ethics requirements for that year.
Upon returning to work, members in these categories will be required to complete CPD under RAID in the year of return before moving onto the formal inputs requirements for subsequent CPD years. ICAEW will (continue to) offer support and guidance to individuals returning to work.
Support for members
ICAEW provides access to a range of high-quality resources to support members in their professional development, including CPD courses, webinars, help sheets and e-learning programmes.
We are producing a series of user-friendly competency frameworks which will support our members working in Audit and Tax. These will help identify areas of development and will direct members to suitable CPD resources.
Members not working in practice
For the CPD year 2022/2023, it is proposed that members not working in practice will continue to follow the RAID requirements, in addition to the new annual ethics requirement.
Additional guidance will be provided to non-practice members on the degree of risk which ICAEW considers to be present in their work. This will help them determine which risk category they are likely to fall into for the 2023/2024 CPD year.
How to respond to this consultation
This consultation closed on Wednesday 18 May 2022. Respondents were asked to consider the following three questions.
- Do you agree with the proposed structural changes to the continuing professional development (CPD) framework outlined in this consultation?
- Do you have any specific feedback or concerns regarding the changes to the CPD framework outlined in this consultation?
- We do not believe the proposed changes will result in a worse outcome or quality of service for anyone due to their background or life circumstances. Please tell us if you think your firm or any of your clients will be adversely impacted by the proposals due to a protected characteristic (such as age, disability or race) or due to your individual practising arrangements?
Following the consultation, the revised CPD Policy will be finalised, and approval will be sought from ICAEW Council. Subject to this approval being granted, ICAEW intends to launch the new policy in November 2022.
Results of the consultation
In total, there were 347 responses to the online consultation.
We were grateful for the responses which the CPD Project Board (consisting of senior executives from across ICAEW) considered carefully prior to finalising the principles of the new policy.
Summary of responses
In consulting on the proposed changes, we asked “do you agree with the proposed structural changes to the continuing professional development (CPD) framework outlined in this consultation?”
There was a small majority of members in favour of revising the CPD requirements:
|Response||No of responses||%|
|Yes – FOR the changes||182||52|
|No – AGAINST the changes||165||48|
The positive responses largely welcomed the move by ICAEW to set a higher requirement for members to keep themselves up to date and operating at the highest standards. Further detailed analysis of the negative responses indicated consistent themes which are set out in the table below together with the CPD Project Board’s comments:
|Concern||Number of times mentioned in responses||Comments|
|1. Concern regarding affordability of CPD resources (for members)||34||There is a wealth of ICAEW CPD content available for members to access, including a range of webinars and events held throughout the year. Many of these are available free of charge or at a reduced price for ICAEW members. Work is underway to ensure that even more free content will be available which will count as verifiable CPD.|
|2. Adverse impact on smaller practitioners – ethics and minimum no of hours requirements||22||In addition to the response to concern 1, ICAEW is developing and will provide, free of charge, an annual ethics learning programme for members to complete to meet the ethics learning requirement (in case they are not undertaking ethics training with the same outcomes in their work training).
All members, working in practice and business, will need to confirm they have met the ethics learning requirements on an annual basis.
|3. Clarity needed regarding impact on retired members||17||The impact on retired members will be clarified in the final policy. The requirement to undertake CPD will depend on whether retired members are engaging in any work.|
|4. Concern that this could create a "tick box" mentality||17||The CPD hours requirements will be a minimum requirement, but the key fundamental principles of RAID (Reflect, Act, Impact, Declare) will remain as the overarching guide. This is to ensure that members continue to complete CPD that is relevant to their role.|
|5. Clarity needed regarding definition of "verifiability"||17||Further, detailed guidance is being developed on verifiability and what constitutes ‘verifiable hours’. We will provide case studies and examples to aid clarity.|
|6. ICAEW should consider impact on part-time workers / reduce hours requirement||11||This has been carefully considered by CPD Project Board. It has been agreed that is not appropriate.|
|7. Clarity needed regarding policy for business members||10||Further clarity will be provided ahead of 2023 implementation. CPD communications will ensure business members are fully aware of the CPD requirements.|
An analysis was also carried out of the positive responses to look for any negative comments contained within those responses. There was a close similarity in the issues mentioned the most in those responses. The issues most mentioned were:
- the affordability of CPD resources;
- the need for a clearer definition of verifiable hours; and
- the impact on retired members.