Belgium CPD: 120 Hours, Two Regimes and a 31 December ESG Deadline

If you are a Belgian réviseur d’entreprises who qualified in 2024 or 2025 and you intend to sign sustainability assurance opinions, there is a 60-hour ESG training requirement with a deadline of 31 December 2026. That is weeks away, and it was already extended once.

Belgium also runs two entirely separate CPD regimes whose headline numbers are identical and whose machinery is not — which catches out anyone who reads one and assumes the other.

The 60-hour ESG deadline

The Institute of Registered Auditors issued a communication in April 2024, following a Council decision of 24 April that year, requiring réviseurs and trainees who passed the aptitude examination in 2024 or by the end of 2025 to complete a minimum 60-hour ESG training programme. Four domains are required:

• legal requirements and standards for preparing sustainability reporting;
• sustainability analysis;
• due diligence on sustainability matters;
• legal requirements and assurance standards for sustainability reporting.

No hour breakdown by domain is given — the 60 hours must simply cover all four.

The original deadline was 31 December 2025. A further communication of 28 May 2025 extended it by one year to 31 December 2026, in light of the EU Omnibus. A separate earlier rule required at least 30 hours by 31 December 2024 for réviseurs signing sustainability assurance opinions in early 2025.

Two conditions worth knowing. Only active réviseurs who complete the 60 hours receive the register mention approving them for sustainability assurance; temporarily prevented auditors are excluded. And the legal basis cited is articles 27 and 79 of the Law of 7 December 2016 — not a royal decree.

One thing neither communication says: whether the 60 ESG hours also count toward the ordinary 120-hour obligation below. We could not establish it, and we are not going to guess at it. If you are planning on that basis, ask the Institute.

Who regulates what — a naming point that matters

The audit regulator is the Collège de supervision des réviseurs d’entreprises, in Dutch the College van toezicht op de bedrijfsrevisoren, which the financial regulator renders in English as the Belgian Audit Oversight Board. It is not the Institute.

The College holds final responsibility for licensing, the register, continuing education, quality control and anti-money-laundering supervision — but it delegates the organisation of continuing education to the Institute while remaining responsible for supervising it. Professional standards themselves are approved by the Conseil supérieur des Professions économiques and the Minister for the Economy, not by the College.

So three bodies touch Belgian audit CPD, and the one that writes the norm is not the one that approves it.

Statutory auditors: 120 hours, and where the detail bites

The obligation sits in article 27 of the Law of 7 December 2016, with the norm-making power in article 31 §1 and the Institute’s organising role in article 79. The instrument is the Norme formation permanente, revised 2020 edition — adopted by Council on 29 January 2021, approved by the Conseil supérieur on 5 February 2021 and by the Minister for the Economy on 10 June 2021, published in the Moniteur belge of 17 June 2021 at page 63658, and in force from 1 January 2022, replacing a norm dating from 2007.

• 120 hours of effective training per three calendar years
• Minimum 20 hours per calendar year, with force-majeure shortfalls makeable up the following year
• Minimum 8 hours per calendar year at the Institute or its ICCI — a delivery requirement, not just an hours one
• Minimum 84 hours per three years in the seminar, workshop, webinar, e-learning, information-session and study-day categories
• Individual reading and private study: capped at 12 hours per three years. Technical committee work and preparing courses or publications are uncapped
• Minimum 84 hours per three years across the first two thematic axes, the second of which covers deontology, independence and firm organisation. There is no standalone ethics hour minimum
• Declaration by 31 March of the following calendar year
• Record retention: minimum 7 years

That 8-hours-at-the-Institute rule is the one most likely to be missed by someone buying training internationally. Hours from an excellent external provider do not discharge it.

Accountants and tax advisers: the same 120, assembled differently

The ITAA regime rests on article 39, fourth paragraph of the Law of 17 March 2019, read with article 72. Its norm was adopted by Council on 1 December 2020 with an avis from the Conseil supérieur dated 20 November 2020, and came into force on 1 January 2021.

• 120 hours per cycle of three consecutive calendar years, minimum 20 per calendar year, pro-rated for proven force majeure or mid-year registration
• Minimum 84 hours across three of the thematic axes combined, one of which covers deontology and anti-money-laundering law. Again no separate ethics minimum
• Category A must be at least 70% — 84 of the 120. Approved seminars, teaching, scientific and technical publications, and qualifying distance learning
• Category B is capped at 30% — 36 of the 120. Institute and committee work, firm or network training
• Distance learning only counts as Category A if it runs at least 30 minutes, blocks the final test until every module is complete, and includes a final test
• Teaching: one hour taught counts as two. Publications: two hours per 3,000 characters. Teaching and publications together capped at 30 hours per calendar year
• Purely promotional training does not count unless it covers useful technical tools, runs at least 45 minutes and has clear objectives
• Declaration: the annual report must be closed no later than two months after the calendar year ends — in practice end of February
• Record retention: 10 years

The contrast to take away

Both professions owe 120 hours over three calendar years with a 20-hour annual floor. Everything else differs:

• Different category systems — the auditors cap private reading at 12 hours per cycle; the accountants cap a whole 30% category at 36.
• Different deadlines — 31 March for auditors, end of February for accountants.
• Different retention — 7 years against 10.

Belgium is also a reminder that the same number can mean different things across borders. France, Spain, Poland, Austria and Greece all land on 120 hours over three years too, from entirely separate instruments — we trace why in our guide to why European CPD keeps converging on that figure, and the legal frame underneath all of them is set out in the EU Statutory Audit Directive, which sets no hours of its own.

On the retention question, Belgium is unusually explicit. Several neighbours state no period at all and impose a duty to produce records on request instead — our guide to CPD record examples covers what to keep either way.

A sourcing note

The figures above come from the two Institutes’ own published norms and communications. One asymmetry worth recording: the auditors’ norm states its ministerial approval and its Moniteur belge page reference; the ITAA norm records only the Conseil supérieur’s opinion and gives no ministerial approval or publication date. We could not establish whether it was published in the Moniteur, so do not assume the two instruments followed the same route.

Frequently asked questions

How many CPD hours do Belgian statutory auditors need? 120 hours of effective training over three calendar years, with at least 20 in any one year and at least 8 of those at the Institute or its ICCI.

And Belgian accountants and tax advisers? The same 120 over three years and 20 a year, but with a 70/30 split between two categories and a different filing deadline.

When is the ESG deadline? 31 December 2026, for a minimum 60-hour programme covering four sustainability domains. It was extended from 31 December 2025.

Do the 60 ESG hours count toward the 120? Not established. Neither communication addresses it — ask the Institute rather than assuming.

How long must records be kept? Seven years for auditors, ten for accountants and tax advisers.

Meet a delivery requirement, not just an hours target, with Learnsignal

Belgium is one of the regimes where who delivers the training is part of the rule — 8 hours a year must come from the Institute, and distance learning only counts in the higher category if it is structured and assessed. Our certificated CPD courses are built to satisfy that kind of condition, with a final assessment and a record of activity, date and duration. The norms and communications cited here are published by the Institut des Réviseurs d’Entreprises.