ICAEW has updated its Continuing Professional Development (CPD) Regulations. The changes are limited in scope and are expected to have minimal impact on members and firms as they principally clarify existing requirements, formalise concessions already set out in guidance and update terminology.
Taking effect from 1 November 2026, the revised regulations retain the existing approach of setting CPD Categories with requirements for minimum hours of learning according to the public interest and the complexity associated with a member’s work.
Record keeping: clarification for firms
The main point for firms to note is a clarification that records must be retained for all CPD completed by staff who are ICAEW members or otherwise ICAEW regulated, not only the verifiable element. Evidence is still required for verifiable CPD, but firms should also keep a record of non-verifiable CPD.
This reflects the intended interpretation of the existing requirement rather than a new policy obligation. The wording has been updated because monitoring activity identified that some firms had interpreted the requirement more narrowly. Firms should check that their systems and processes capture all relevant CPD activity and retain those records for three years from the end of the CPD year.
Confirmation of verifiable ethics CPD
Another clarification is that the mandatory minimum of one hour of ethics training must be verifiable. Members can meet this requirement by completing the ICAEW ethics module during the relevant CPD year (or in an earlier CPD year if they have not already done so), or by undertaking alternative ethics training that can be evidenced and meets specified learning outcomes aligned with the ICAEW Code of Ethics.
Existing concessions formalised
Two concessions currently set out in guidance have been incorporated into the regulations. This gives them a clearer formal basis but should not change the position for members who already rely on the concessions set out in the guidance
Reflect without minimum hours
- Members whose gross annual income from paid accountancy work is less than £1,000, or whose only relevant role is acting as a statutory director of a micro entity, will only be required to reflect on their professional development needs, create a plan for meeting those needs, and undertake any necessary training - with no minimum hours’ requirement. They must still maintain CPD records and provide them if requested by ICAEW.
Exemption for trustees
- Members acting solely as a trustee for a trust of a low-risk or personal nature (as defined) will be exempt from the CPD Regulations if they do no other work or hold no other roles that would bring them within the scope of the regulations.
Terminology and other clarifications
The regulations also include a small number of terminology updates to reflect wider regulatory and organisational changes. These include:
- updated terms for the incoming local audit regulatory regime, including replacing ‘Key Audit Partner’ with ‘Lead Partner’;
- references to ICAEW’s wider role as a legal services regulator, including its regulation of Oaths work;
- the change of the division name from the Professional Standards Department to Regulation & Conduct; and
- updated names for relevant internal teams, including the Adjudication team.
ICAEW monitoring of CPD compliance
A regulation has also been added allowing immediate referral to the Conduct Department where members fail to provide CPD records to QAD on request or otherwise do not co-operate with ICAEW in relation to a CPD check.
What firms should do
Most firms and members will not need to change their approach. However, firms’ compliance principals should ensure that all CPD undertaken by members and other relevant individuals within scope is recorded, that evidence of the verifiable element is kept, and that these records are retained for three years.
Any members or regulated individuals relying on one of the formalised concessions should ensure they understand the conditions that apply, and for those who are required to undertake CPD but no minimum hours, ensure they comply with the continuing requirement to reflect on their needs, implement an action plan to address those needs, undertake appropriate training, and maintain records where relevant.
More information
CPD Regulations
ICAEW has updated its Continuing Professional Development (CPD) Regulations, effective from 1 November 2026.
Read the regulations