How to Record Non-Verifiable CPD for ACCA

ACCA says you do not need to provide evidence for non-verifiable CPD. ACCA's Membership Regulations also require you to keep records of your non-verifiable units. Both statements are true, and the apparent contradiction between them is why this is the part of the requirement members get wrong most often.

Evidence and records are not the same thing

Take the two provisions separately.

Membership Regulation 4(4)(e)(i) requires individuals subject to the CPD requirement to maintain records of both verifiable and non-verifiable units obtained, and of the relevance of those units to their role. In the case of verifiable units, the records must additionally include proof that the individual was involved in an acceptable learning activity.

ACCA's guidance then says, of non-verifiable CPD, that you do not need to provide evidence for it.

Read together, the position is straightforward. You must record that the activity happened and why it was relevant to your work. You do not have to hold a certificate, attendance confirmation or third-party document proving it. The record is your own; the evidence requirement is what is waived.

That distinction matters because members who read only the guidance sentence sometimes keep no non-verifiable record at all, and the record-production duty in regulation 4(4)(e)(ii) applies to the whole record, not just the verifiable part. Failure to produce records on request is one of the three breaches that can lead to removal from the register, as we set out in our analysis of ACCA's declaration and compliance data.

What counts as non-verifiable

ACCA's quick guide defines non-verifiable CPD as general learning not related to a specific outcome, or which is difficult to provide evidence for. Its routes guidance puts it as general learning, such as reading or research, which is not related to any specific learning outcome or objective.

So the category is defined by two things: the absence of a specific learning outcome, and the practical difficulty of evidencing it. Technical reading, keeping up with developments in your field, informal discussion with colleagues and self-directed research are the typical examples.

The useful test runs the other way round. A unit is verifiable, in the words of Membership Regulation 4(4)(d)(ii), if you can prove you were involved in an acceptable learning activity, and non-verifiable if you cannot. Note that the regulation's test is provability alone. ACCA's guidance adds two further limbs, framing verifiability as three questions: 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. Those three questions are guidance, not the rule, and the difference is covered in our piece on why ACCA's 40-unit rule applies to only one of three routes.

A practical consequence: an activity you could evidence but chose not to is, on the regulation's test, verifiable. Keeping the certificate for a webinar converts it. Deciding not to does not make the hour non-verifiable in principle, it just means you cannot count it as verifiable when asked.

The 19 is a ceiling, not a target

This is the most common misreading of the whole requirement, and it causes real wasted effort.

Regulation 4(4)(d)(i) requires at least 40 units per calendar year. Regulation 4(4)(d)(ii) requires at least 21 of them to be verifiable. ACCA's guidance then describes up to 19 non-verifiable units.

So 40 is a floor, 21 is a floor, and 19 is a cap on how much of the 40 may be non-verifiable. It is not a second quota to be filled. A member who completes 40 verifiable units and no non-verifiable units has complied fully. Presenting 21 and 19 as two targets, as a great many summaries do, overstates what the regulation asks for.

The practical reading: you need 40 hours of relevant development, of which at least 21 must be provable. How you make up the rest is your choice, and reading counts.

Non-verifiable units cannot be carried forward

Carry-forward applies to verifiable units only. ACCA's guidance is explicit that non-verifiable units cannot be carried forward, and that nothing at all can be carried into a member's first CPD year.

One honest caveat on the carry-forward trigger itself, because two ACCA pages describe it differently. The routes guidance says that completing more than 21 verifiable units in a year lets you 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: a member with 25 verifiable and 10 non-verifiable units has exceeded 21 verifiable but not 40 in total. We could not reconcile the two from primary sources, so treat the mechanics as unsettled and confirm with ACCA before relying on a carry-forward.

What a non-verifiable record should actually contain

The regulation asks for two things: that the unit was obtained, and its relevance to your role. In practice that means a line per activity with the date, what it was, roughly how long it took, and one sentence on why it mattered to your work.

The relevance sentence is the part worth doing properly, because relevance is a regulatory requirement in its own right. Regulation 4(4)(d)(iv) requires members to obtain their units in areas relevant to their work, and regulation 4(4)(d)(v) requires every member, regardless of role, to maintain competence in professional ethics and keep their business and finance knowledge up to date. A record that says only that you read technical articles for four hours satisfies the first limb and not the second.

Retention is three years as a baseline under regulation 4(4)(e)(ii), with longer periods in specific cases: six years for responsible individuals, Irish sustainability assurance providers and certain Irish auditing certificate holders, and five years for registered tax practitioners in South Africa. If you are selected for review, ACCA asks for records within 28 days of the notification email.

Two things that are not non-verifiable CPD

First, time spent on something irrelevant to your role is not CPD at all, verifiable or otherwise. The relevance condition sits above the verifiable split rather than inside it.

Second, on the ACCA Approved Employer route the distinction does not apply, because that route counts no units. ACCA's guidance for it states that members will not need to document or keep evidence of individual CPD units, demonstrating instead that they have taken part in their employer's development and appraisal process. Members on that route who spend time categorising reading as non-verifiable are doing work the route does not ask for.

For the full requirement including what the annual declaration asks and how reviews work, see our guide to ACCA CPD requirements. ACCA's own statement of what to keep is published on its keeping CPD evidence page, and that is the page to check before a review rather than any third-party summary, including this one.