CA ANZ Runs Two CPD Philosophies, and Only One Counts Hours

CA ANZ runs two different CPD philosophies inside one organisation. For its general membership the requirement is a number of hours. For licensed auditors in New Zealand it is a plan, a self-assessment and a set of learning outcomes — and CA ANZ says so in terms, describing its policy as incorporating International Education Standard IES 8, "an output based education model".

That is the only place in either major Australasian body's material where an explicit output-based model is claimed, and it makes the New Zealand audit regime the most substantively different CPD scheme either body operates.

Why there are two regimes

CA ANZ's Regulation CR 7 is divided into schedules. Two of them cover the general membership, split by residence rather than by where the member practises — so an Australian-resident CA auditing in New Zealand sits in the first, and a New Zealand-resident CA sits in the second wherever they work. Both are hours-based.

The third schedule is different in kind. It applies to licensed auditors in New Zealand and to engagement partners on public interest entity audits, and it does not work by counting hours at all.

The reason is that CA ANZ is not the only authority in play. New Zealand's Financial Markets Authority sets requirements under section 18 of the Auditor Regulation Act 2011, and NZICA is the licensing body. CA ANZ's own page puts the relationship plainly: licensed auditors need to comply with its CPD policy as well as the requirements prescribed by the FMA under section 18. Australia's equivalent regulator, ASIC, requires registered company auditors to complete continuing professional development over each three-year period, but it does so in hours.

What an output-based regime actually asks of you

The third schedule requires a self-assessment, a prioritised learning plan covering no more than three years with annual updates, supporting evidence, and tracking against the learning outcomes set out in the schedule's own appendix. Engagement partners conducting public interest entity audits were required to assess their competencies by 1 July 2019, and the reporting period is a triennium commencing from 1 July 2019 and each subsequent triennium.

Notice what is absent: a quantum. There is no number of hours to reach and therefore no way to discharge the obligation by accumulating attendance. The question is whether the plan addresses the competencies the role requires and whether the evidence shows it was followed.

That is a materially harder thing to demonstrate than a total, and a materially easier thing to do badly. An hours requirement can be satisfied by a member who learned nothing; an outcomes requirement can be failed by a member who learned a great deal in the wrong areas.

The monitoring is external, and so is the sanction

For the general membership, CA ANZ monitors the CPD records of a random selection of members, and publishes no sample size or percentage anywhere we could find. Certificate of public practice holders are additionally monitored through practice review.

For licensed auditors the position is different on both counts. The FMA and NZICA review licensed auditors, with the FMA conducting quality reviews under section 65 of the Auditor Regulation Act; CA ANZ reviews engagement partners through its own quality review programme.

And the consequence is not a membership matter. NZICA may vary, add to, suspend or cancel an audit licence for CPD non-compliance. For the general membership the worst outcome under CR 7.7 and By-Law 23(c) is exclusion from membership; for a New Zealand licensed auditor, failure here costs the licence to do the work.

There is no CPA Australia analogue to losing an audit licence through its own CPD regime. CPA Australia's By-Law 4.5 takes a different route entirely: it makes the external regulator's requirement a membership obligation, so a lapse with the regulator is also a by-law breach, but the by-law itself sets no hours and no outcomes.

Entry differs too, and this is a clean Australia and New Zealand contrast

For a certificate of public practice, CA ANZ's Australian process lists having met CPD requirements among the conditions of applying. The New Zealand process asks applicants to present their past two years of CPD records, and states that it is important to be up to date in your area of practice.

So Australia asks whether the requirement was met; New Zealand asks to see the evidence and forms a view on currency. One is a declaration, the other is a review.

Applications route differently as well. New Zealand residents apply through NZICA; members not based in New Zealand can apply direct to the Companies Office for recognition, and those outside New Zealand performing Financial Markets Conduct Act audits apply to the FMA. The statutory framework cited on CA ANZ's own New Zealand audit page runs across sections 18, 20(1)(a), 65 and 75 of the Auditor Regulation Act 2011, section 36 of the Financial Reporting Act 2013, and the Financial Markets Conduct Act 2013.

Why this matters beyond New Zealand

Two reasons, one practical and one conceptual.

The practical one is that a member can move between the two regimes without moving jobs. CR 7's schedules turn on residence, and the third schedule turns on being a licensed auditor or a public interest entity engagement partner. A CA who takes on a public interest entity engagement acquires a plan-and-outcome obligation that their hours log does not satisfy.

The conceptual one is more interesting. The international standard that sits behind all of this places its obligation on the member body rather than on the individual, and prescribes no hours figure in any of its requirements — a point we set out in our explainer on where accountants' CPD requirements come from. Bodies are free to choose, and almost all of them choose hours, because hours are administrable. CA ANZ's third schedule is evidence that the same body will choose outcomes when the stakes are high enough and an external regulator is watching.

Which is worth holding onto when reading any body's claim about its own approach. Neither CA ANZ nor CPA Australia characterises its general scheme as input-based or output-based anywhere we could find; both simply count hours. The only explicit claim of an output-based model in either body's material is this one, and it applies to a small population under statutory supervision.

Two caveats on sourcing

CA ANZ's current CR 7 sits behind its MyCA member login and could not be retrieved. The publicly downloadable edition is marked "Issued 8 October 2019" and is superseded on several points. The third schedule's requirements described above come from that 2019 edition, and we could not confirm whether its appendix of learning outcomes has been revised since. Treat the structure as reliable and the detail as needing a check against the current regulation.

Separately, we found no CA ANZ primary-source statement of the CPD quantum for Australian financial advisers or New Zealand financial advice providers, both of which are set by law rather than by CA ANZ, so we are not supplying figures for either.

For how the general membership requirement works, including the classes where 120 hours is the wrong number, see our piece on CA ANZ CPD hours by membership class, and for how the whole regime compares with the other major Australian body, CPA Australia versus CA ANZ. CA ANZ's own account of New Zealand audit regulation, including the IES 8 statement, is on its New Zealand audit regulation page.