Fewer Than Half of ACCA Members Meet the CPD Declaration Deadline

ACCA publishes how many of its members meet the annual CPD declaration deadline. The figure is 46.26%. It appears in ACCA's own Report on Regulation and, as far as we can establish, nowhere else in the commentary on ACCA CPD. The number usually quoted instead is 89.35%, which measures something different and is taken three months later.

Two compliance figures, three months apart

ACCA's Report on Regulation 2025 covers the year ended 31 December 2024 and reports declaration status as at 1 April 2025. On that basis it states that "the number of members required to submit CPD declarations for 2024 who remain on the active register was 228,229" and that "Of these, 203,930 (89.35%) have submitted CPD declarations for 2024 confirming compliance."

Separately, the same report gives the proportion submitted on or before the 1 January 2025 deadline as 46.26%. The two numbers are not alternative readings of the same thing and should not be combined. One is compliance at a date three months after the deadline; the other is compliance at the deadline itself. Fewer than half of the members who owed a 2024 declaration filed it on time.

That gap is a fact about behaviour rather than about the rule, and it is the more useful of the two numbers for anyone planning when to prompt members, sell CPD, or schedule a December learning push.

Why the deadline is so easily missed

The structure invites it. ACCA's CPD year is the calendar year: Membership Regulation 4(4) requires at least 40 units per calendar year. The declaration for that year is due by 1 January — the day after the year ends. There is no grace period built into the regulation, and ACCA's guidance states it plainly: "You must submit your declaration by 1 January of the following year."

So a member finishing their last verifiable unit in late December has, on the face of the rule, no working days in which to reflect on the year and declare it. ACCA's own deadline-related material is correspondingly insistent, telling members who have missed it that "it's extremely important that you send it to ACCA as soon as possible."

The declaration is owed on every route. ACCA states that "Every member* must submit an annual CPD declaration, no matter which CPD route you're following", with the only exceptions being lifetime members and new members in their first year of membership. That includes members following an Approved Employer programme or another IFAC body's scheme, where no ACCA unit count applies at all — as set out in our analysis of how ACCA's 40-unit rule applies to only one of three routes. Members granted a waiver are not excused the declaration either.

How much review actually happens

ACCA reviews a statistical sample of members' CPD each year, weighted towards risk groups: practising members, audit engagement partners, follow-ups from earlier reviews, referrals from regulatory or Approved Employer monitoring, and members with missing declarations. CPD records are additionally checked during audit firm monitoring visits, desktop monitoring and Approved Employer visits.

The volume is published. ACCA reviewed 5,433 CPD records in 2024, up from 4,186 in 2023. What is not published is the sample expressed as a percentage of the membership, and the 5,433 figure mixes the statistical sample with risk-based and visit-based selections, so dividing it by the membership does not produce a sampling rate. Any source quoting ACCA's CPD sampling percentage is quoting a number ACCA does not publish.

A member selected for review is notified by email and has 28 days to submit records. ACCA states it will check that the member has met the requirement for the route they are following, provides feedback on the activities, and also asks the member to complete a CPD activities questionnaire. Non-cooperation has its own consequence: ACCA states that members who do not cooperate with the review process may be removed from the register.

What removal actually looks like

Removal happens, at a low rate, and ACCA quantifies it. "The percentage of members removed for CPD default in 2024 was 0.36%", which the report explains "equates to 796 members – 633 for missing CPD declarations and 163 for not cooperating with the CPD review process." The 2023 comparative was 0.37%, and the 2024 figure was measured against a 0.50% benchmark.

Read the composition of that number carefully. All 796 removals were for a declaration failure or a review-cooperation failure. None are attributed to having done too little CPD.

That matches the regulation. Membership Regulation 12 triggers removal for breaches of the declaration requirement, the requirement to produce records on request, and the conditions attached to any variation granted — where the breach has not been remedied within three months. A pure learning shortfall, honestly declared, is not on that list. ACCA's own guidance for a member in that position routes them into support rather than discipline: they must still declare that they have not met the requirement, ACCA will contact them about making it up, they submit an updated declaration once they have, and any CPD done in the following year goes first to clearing the shortfall.

This is the single most misreported aspect of ACCA CPD enforcement. The sanction attaches to the paperwork and the cooperation, not to the hours.

The timetable is shorter for audit-qualified practitioners

ACCA states two operational thresholds. Members who fail to submit declarations confirming compliance for two consecutive years are removed. Members holding a UK or Irish practising certificate and audit qualification who fail to submit for one year are removed.

Two points of precision. First, the quantum of CPD does not differ for practising members — 40 units with at least 21 verifiable applies equally. What differs is the enforcement timetable. Second, the shorter timetable is tied specifically to holding a practising certificate and audit qualification, not to holding a practising certificate alone, so writing that practising certificate holders face one-year removal overstates the population caught.

These operational thresholds sit alongside, not instead of, the regulation's three-month remedy window. The regulation is the rule; the two-year and one-year thresholds are how ACCA describes applying it.

Where the hard wording lives

Anyone quoting the consequences of CPD non-compliance should quote the Rulebook, because ACCA's member-facing pages are materially softer. The page for members who have not met the requirement contains no reference to removal from the register and no disciplinary language; the leaflet for members who have not submitted a declaration says only that not submitting "will put your membership at risk." The mandatory removal wording exists in Membership Regulation 12 and the declaration duty in Membership Regulation 4(4)(c).

Record retention is governed by the same regulation: records of both verifiable and non-verifiable units and of their relevance, retained for three years as a baseline, with longer periods in specific cases. Our guide to the ACCA annual declaration, reviews and retention covers the mechanics, and where accountants' CPD requirements come from explains why ACCA is free to set these numbers in the first place.

One note on oversight, from ACCA's own account: the Financial Reporting Council's latest report added a new requirement on inadequate CPD review, and three prior-year FRC recommendations relating to CPD remain open. Every figure above is published by ACCA in its Report on Regulation 2025, and the figures move annually, so check the current edition before relying on any of them.