ACCA's 40-Unit CPD Rule Applies to Only One of Three Routes

Almost every description of ACCA's continuing professional development requirement says the same thing: 40 units a year, of which at least 21 must be verifiable. That is accurate for most members and wrong as a general statement. ACCA's own Membership Regulations set out three ways a member may obtain CPD, and the 40-unit scheme is only one of them. On another of the three, the member keeps no unit records at all.

Where the obligation sits

The duty is in Membership Regulation 4(4) of the Chartered Certified Accountants' Membership Regulations, part of the ACCA Rulebook. The edition in force is the one amended 1 January 2025. ACCA's own 2026 Rulebook commentary lists amendments to Membership Regulations 3, 4(3) and 6(3) but leaves regulation 4(4) and regulation 12 untouched, so the 2025 text is still the operative rule for 2026.

Two features of the regulation get dropped in retelling. The first is that the duty has two limbs: a member must obtain CPD and must be able to demonstrate that they have obtained it. Most summaries quote only the first. The second is that regulation 4(4)(b) enumerates three ways of obtaining it — with an employer holding approved CPD employer status from ACCA, by following the unit scheme in the regulations that follow, or by following the CPD scheme of another IFAC body of which the member is also a member, provided that scheme complies with IFAC's CPD requirements.

Route one: the unit scheme

This is the route the familiar numbers belong to, and ACCA describes it plainly: "You'll complete a total of 40 relevant units of CPD each year, comprising: at least 21 verifiable units; and up to 19 non-verifiable units." One unit equals one hour of development, so despite the vocabulary ACCA is an hours-counting body.

The arithmetic is more permissive than it looks. The regulation sets a floor of 40 units and a floor of 21 verifiable units. The 19 is a ceiling on how much of the 40 may be non-verifiable, not a second quota to be filled. A member who completes 40 verifiable units and no non-verifiable ones has complied. Presenting 21 and 19 as two targets, as a great many summaries do, overstates the requirement.

Carry-forward exists but should be stated carefully, because two ACCA pages describe its trigger differently. The routes guidance says that completing more than 21 verifiable units in a year lets a member carry forward up to 21 of the additional units; ACCA's knowledge-base article frames the trigger as completing more than 40 units in the year. Those are not the same test. What both state consistently is that non-verifiable units cannot be carried forward, and that nothing can be carried into a member's first CPD year.

Route two: the Approved Employer route, which counts nothing

This is the finding that undoes the standard description. Where a member works for an employer holding ACCA Approved Employer professional development approval, they follow the employer's own development programme instead. ACCA's guidance for that stream states that such members "will not need to document or keep evidence of individual CPD units".

No units. No unit evidence. If selected for review, the member instead has to "demonstrate that they have taken part in your company's development and appraisal process". The burden shifts substantially to the employer, which must operate a documented process letting its ACCA members review their learning needs regularly and discuss relevance and application with a line manager "at least once every 12 months". The member remains, in ACCA's words, "individually responsible for identifying and completing development activities that are relevant to their own role and career ambitions" — but against no numeric standard.

The annual declaration is still required. A member on this route declares that they have followed it, and a member who worked for an Approved Employer for only part of the year may still indicate that route when declaring.

Route three: another IFAC body's scheme

A member who also belongs to another professional body may follow that body's CPD programme instead, subject to three conditions ACCA states as a checklist: full membership of the other body, that body being a member of IFAC, and its CPD policy complying with International Education Standard 7. Our explainer on where accountants' CPD requirements come from sets out what IES 7 does and does not require, which matters here because the third condition is the one a member is least able to assess for themselves.

The route is not a shield from scrutiny. ACCA reserves the right to check with the other body, and members holding an ACCA practising certificate and audit qualification are required to submit full CPD records if selected for a CPD review regardless.

The fourth route ACCA's guidance adds

ACCA's member-facing pages present four routes, not three. The additional one is for part-time or semi-retired members, and it is a variation inside the unit scheme rather than a separate regulatory route. Eligibility turns on being "employed for 770 hours or less during a CPD year", which ACCA notes "works out at 17.5 hours per week" and which its own guidance PDF characterises as a guideline rather than a hard test.

What makes this route remarkable is the requirement it replaces the numbers with: "you'll complete 19 units of non-verifiable CPD" and "You'll set your own level of verifiable CPD, but please ensure that it's enough for your current role." The verifiable floor disappears entirely and becomes the member's own judgement.

The exclusions are correspondingly firm. A practising member may use the route only if not responsible for audit or other regulated report work. Members involved in the preparation or presentation of accounts investors may rely on, and non-executive directors of listed companies, are told they should not follow it and must complete the full unit route even below 770 hours.

Verifiable means something narrower in the rulebook than in the guidance

ACCA's guidance frames verifiability as three questions a member must be able to answer yes to: was the activity relevant to your career, can you explain how you applied the learning in the workplace, and can you provide evidence that you undertook it. That formulation appears consistently across ACCA's quick guide, its guide to CPD and its practising-members PDF.

The regulation is narrower. Regulation 4(4)(d)(ii) turns verifiability on provability alone: a unit is verifiable if the member can prove they were involved in an acceptable CPD learning activity, and non-verifiable if they cannot. Relevance and application are in the guidance, not the rule. Anyone citing the three questions as ACCA's requirement is citing guidance. The distinction matters whenever the question is what a member can be held to, which is also the distinction at the heart of what CPD accredited actually means.

Two topic obligations that bind every member

One part of regulation 4(4) is missed even more often than the routes, and it is the only place the regulation names subject matter. Regulation 4(4)(d)(v) requires that all members, regardless of their role, maintain competence in professional ethics and keep their business and finance knowledge up to date. Regulation 4(4)(d)(iv) requires members to obtain their units in areas relevant to their work.

Read that carefully, because it is easy to both over- and under-state. Ethics is a named, mandatory competence obligation on every member. It is not a quota: no sub-paragraph of regulation 4(4) attaches a number of units to ethics, and nothing requires ethics CPD to be verifiable rather than non-verifiable. Any statement that a member must include a given number of ethics units, or must place ethics inside their verifiable units, is adding a requirement the regulation does not contain.

The one place the regulation does require a proportion is elsewhere: practising members must maintain competence in the specialised areas of their practice and obtain an appropriate proportion of their units in those areas. ACCA's guidance restates the ethics duty for practising members and firms in the same terms.

The ACCA Ethics and Professional Skills module is a different thing again, and the two are frequently conflated. ACCA's regulations define it as an online module forming a mandatory component of the ACCA Qualification, and completing it is a condition of admission to membership. For existing members it is available free of charge and is optional. It is not part of the 40-unit requirement.

There is also a genuine ethics quota that belongs to a different regulator entirely. ACCA's guidance for practising members records that the South African Revenue Service requires registered tax practitioners to complete at least 18 hours of CPD a year, of which at least ten must be tax, six must relate to services provided and two must be ethics. That is a SARS requirement inside a SARS scheme, binding only ACCA members in South Africa who are registered tax practitioners. It is not ACCA's 40-unit scheme and it binds nobody outside that group — which is one way a two-hour ethics figure finds its way into general descriptions of ACCA CPD where it does not belong.

Who sits outside the requirement

Members on the register of lifetime members are not required to undertake CPD at all. New members do not complete CPD in their first calendar year of membership and begin from 1 January of the year after admission — a grace period worth contrasting with bodies whose obligation starts on election. Affiliates are told they should focus on the practical experience requirement, in guidance that uses "should" and attaches no quantum.

In the other direction, ACCA's Global Practising Regulations extend Membership Regulation 4(4) to certain people who are not ACCA members at all: non-member principals and agents of firms carrying on regulated activities in the UK and the Crown Dependencies, and non-member responsible individuals in firms holding an auditing certificate, each required to comply as if they were members.

Why the route matters more than the number

For a member, the practical question is not how many units to do but which route they are on, because the routes impose genuinely different duties: a counted 40 with a 21 floor, a self-set verifiable level, an appraisal process with no units, or another body's scheme entirely. For anyone buying or supplying CPD, the Approved Employer route is the one to understand, because on it the unit arithmetic that most of the market sells against does not apply.

The record-keeping duty survives all of it. Members must keep records of both verifiable and non-verifiable units and of their relevance, for three years as a baseline — longer in specific cases, as our guide to the ACCA annual declaration and record retention sets out. The routes themselves are published on ACCA's own guide to CPD routes, and a member unsure which one applies should read it there rather than relying on any third-party summary of the 40-unit figure.