CPA Australia's 10-Hour Ethics CPD Rule Bites in Full This Year

CPA Australia members have an ethics CPD obligation that most summaries of the requirement omit entirely, and for a large cohort of members the full version of it bites for the first time at the end of this year.

The requirement nobody quotes

Everyone knows the headline: 120 hours per triennium, at least 20 in each year. That is By-Law 4.1(a) and it is correct.

By-Law 4.1(b) then adds a second, narrower obligation. Within the 120 hours of each triennium, members must undertake at least 10 hours of Ethics and Professional Responsibility, of which at least 2 hours must be undertaken in each year of the triennium.

Note the structure, because it is the part most often got wrong in the other direction: the 10 hours sit inside the 120, not on top of it. CPA Australia's own guidance confirms that the required ethics CPD hours are not an additional CPD requirement.

So the complete quantum is a four-part test, not a two-part one: 120 per triennium, 20 per year, 10 ethics per triennium, 2 ethics per year.

Why this year is different

The obligation was phased in, and CPA Australia publishes the schedule. By triennium ending: 2023, none. 2024, two hours minimum with no overall obligation. 2025, two hours minimum for 2024 and 2025 respectively, with no overall obligations. 2026, two hours per year with an overall obligation of 10 hours for the triennium.

So the triennium ending 31 December 2026 is the first in which the full 10-hour figure applies. Members in that cohort who have been tracking the two-hour annual minimum and nothing more may find themselves several hours short with weeks rather than months to close the gap.

One caveat we should flag rather than bury: that phase-in table appears in CPA Australia's guidance. By-Law 4.1(b) states the 10-hour obligation flatly, with no transitional provision in the by-law itself. The guidance dates the requirement from October 2023 onwards.

Which triennium you are in, exactly

This matters more than usual this year, and it is widely misdescribed.

By-Law 4.3 fixes the triennium by reference to the member's date of admission. Members admitted before 30 June in any year are deemed to have commenced their triennium on 1 January of that year; members admitted on or after 30 June commence on 1 January of the following year. Members admitted before 31 December 1998 have a commencement date of 1 January 1999.

So CPA Australia's triennium is calendar-year aligned, running 1 January to 31 December across three full years, and cohorted by admission date. It is not the Australian financial year. It is not an anniversary cycle. And although CPA Australia's own guidance calls it a rolling three-year review period tied to when you joined, it is not a continuously rolling window either — By-Law 4.3 fixes a commencement date.

That 1 January alignment is also the single most consequential difference for anyone who also belongs to another Australian body, since Chartered Accountants Australia and New Zealand runs 1 July to 30 June. The same learning lands in different triennium-years for each.

The evidence rule that is not in the by-law

Here is a gap worth understanding before relying on anything.

CPA Australia's guidance states that all ethics-related CPD activities must be verifiable and supported by appropriate evidence of completion, and gives examples: confirmation of attendance, exam results, certificates of completion or certificates of achievement. It also states that presentation slides, registration emails and general course materials are not sufficient for verification purposes.

By-Law 4.1(b) contains no such requirement. Its operative words are only that members must undertake at least 10 hours of Ethics and Professional Responsibility. The word verifiable does not appear. Nor does any verifiable, structured or technical sub-quota appear anywhere else in the By-Laws, for the ethics hours or for the other 110.

The only binding evidential duty is in By-Law 4.2(a), and its test is production rather than verification: members must maintain a record of the precise nature of their CPD including dates, time expended and topics covered, retain that record for at least 12 months after the end of each triennium, and produce it to an officer of CPA Australia for inspection upon request.

This is the same pattern we found in ACCA's rulebook, where the familiar three-question test for verifiable CPD turns out to be guidance while the regulation's own test is provability alone, as set out in our piece on how ACCA's 40-unit rule applies to only one of three routes. The practical reading is the same in both cases: follow the guidance, because it is what a reviewer will apply, but know that the binding obligation is narrower than the guidance describes.

Who is exempt, and the trap in it

By-Law 4.1(b) is subject to the exemptions in 4.1(b) and to By-Laws 4.5 and 4.6. Life Members, Honorary Members and members on the Retired Membership List are exempt.

The Retired Membership List conditions are worth stating precisely, because they are more generous on age and less generous on activity than people assume. A member may be placed on the list if they have attained the age of 55 years and, as a continuing requirement, are not engaged in full-time gainful employment, and do not hold and are not required to hold a Public Practice Certificate.

Then the trap. By-Law 3.11(b) withdraws the exemption where the member provides any public accounting services, whether or not provided for reward, including pro bono work. Volunteer treasurer work for a community organisation is enough to restore the full 120 hours, ethics included.

Note also what is absent. There is no career-break, parental-leave, part-time or non-practising exemption anywhere in CPA Australia's By-Laws. The binding reliefs are Life Member, Honorary Member and the Retired List, and nothing else. CPA Australia's guidance refers to a partial CPD exemption, and we could not locate it in any binding instrument. Where a partial exemption is granted, the guidance states that a member will not receive an exemption for CPD obligations for Ethics.

What happens if you are short

Less than people fear, at least at first, and the sequence matters.

By-Law 4.4(a) provides that where a member fails to undertake the required amount of CPD, or fails to produce the record on request, CPA Australia may investigate, require information, and cause the member to enter a formal agreement to complete the required CPD within a prescribed timeframe — explicitly excluding the requirements of the following triennium, so make-up hours cannot be double-counted. Only if the member then fails to comply with that direction does By-Law 4.4(b) make it a breach of a requirement of membership under Article 9(a) of the Constitution, and an Adverse Event.

So CPA Australia cannot discipline a member merely for being short on hours. The architecture is remedial first.

What is counter-intuitive is the asymmetry in how the two failures are treated in practice. On CPA Australia's own account, a member who fails to provide a CPD record is referred to the Professional Conduct Unit for investigation and disciplinary action, while a member who fails to meet the requirements is placed on a CPD Support Plan. Not producing the records is handled more harshly than not doing the learning.

For scale: CPA Australia reports requesting CPD records from a sample of members across its global membership, with 850 members selected for review in 2024, and records that the new ethics requirement has been brought inside the scope of that review. We are not going to convert 850 into a percentage, because CPA Australia does not publish the denominator alongside it.

What to do in the next few weeks

Check which triennium you are in using By-Law 4.3 rather than a memory of when you joined. If it ends on 31 December 2026, total your ethics hours for 2024, 2025 and 2026 separately — you need two in each year and ten across the three. Make sure what you hold for each is a certificate or confirmation of attendance rather than slides or a registration email. And if you are on the Retired Membership List and have done any accounting work for anyone, paid or not, assume the exemption has lapsed.

The requirement is a reminder that an hours total travels with its sub-quotas or it misleads, which is the same conclusion our comparison of why Ahpra CPD hours are not comparable across National Boards reaches for Australian health practitioners, and the reason any of these figures exist at all is covered in our explainer on IES 7. CPA Australia's own statement of the ethics requirement, including the phase-in table, is on its ethics requirements for CPD page, and the By-Laws currently in force are the edition effective 1 October 2026.