Yukon’s AML Deadline Is a Year Later Than BC’s, and Four More Canadian Gaps Closed

We have been documenting Canadian CPA continuing development province by province and have repeatedly left cells blank rather than assume a figure. Five of those blanks are now filled, and two of them turned out to be places where the assumption would have been wrong.

The headline: Yukon has British Columbia's anti-money-laundering requirement, at the same 1.5 hours, with a deadline a full year later. And Prince Edward Island does require four ethics hours, despite its binding regulations never mentioning ethics at all.

Yukon does not simply mirror British Columbia

Yukon's rules are published by CPABC as a separate document, the CPA Yukon Bylaw Regulations, in a May 2026 edition, and the continuing development provisions sit in a 600-series just as British Columbia's do. The headline figures are identical: 20 qualifying hours a calendar year including at least 10 verifiable, and 120 hours over each rolling three-calendar-year period including at least 60 verifiable, of which at least four are ethics hours.

Regulation 600/5 sets the reporting deadline at 31 January and regulation 601/1 gives a later date of 31 March for members covered by the equivalent of British Columbia's late-completion bylaw. Regulation 600/6 requires documentation supporting verifiable hours to be kept for at least five years after the end of the calendar year. Regulation 600/3 adds post-admission coursework for certain foreign-qualified members, waived on passing the reciprocity examination.

The divergence is the anti-money-laundering rule. Regulation 600/2.1(1) requires every member to complete at least 1.5 anti-money-laundering hours by the later of 31 December 2027, or the end of the second calendar year following initial admission. British Columbia's equivalent date is 31 December 2026.

So a dual-registered member holding both has two different deadlines for the same 1.5 hours, a year apart. And anyone who read our note that British Columbia's anti-money-laundering hours fall due at the end of 2026 should not carry that date north. As in BC, the hours may count as ethics hours for the relevant period.

The consequences sit in a separate CPA Yukon Bylaws document, and they do match British Columbia's. Bylaw 602(1) suspends membership where a member fails to deliver the annual compliance report or comply with the programme by the further deadline, until they deliver the report, satisfy outstanding requirements and pay any administrative fee the board prescribes. Bylaw 602(2) requires "at least 30 days before a suspension under subsection (1) can take effect" that Yukon deliver notice of the effective date, the reason, and how to apply to the Membership Committee for relief. Bylaw 602(3) cancels membership where the requirements are not met "within 90 days of the date the suspension takes effect", and 602(4) lets the Membership Committee order in special circumstances that a suspension or cancellation not occur or be delayed. Bylaw 603 allows a discretionary referral to the Investigation Committee where an investigation appears warranted.

So the same ladder and the same thirty and ninety day periods as British Columbia, with the anti-money-laundering deadline the one real divergence. One caveat on currency: the only CPA Yukon Bylaws edition we could find is dated August 2023, while the Bylaw Regulations carrying the hours are a May 2026 edition, so whether bylaws 600 to 603 were amended in between is not established.

The Northwest Territories and Nunavut publish the most detailed penalty schedule in Canada

CPA NWT/NU's requirements sit in a board policy, version 2024.05, citing no bylaw or regulation number and referring only generally to the bylaws on reinstatement. The hours match the national pattern: 20 reported annually with 10 verifiable, 120 on a rolling three-calendar-year basis with 60 verifiable, and four verifiable ethics hours every three years. Public practice members need a further 10 mandatory verifiable hours directly related to public accounting competencies. Hours must be recorded by 31 March following the reporting year.

Two features stand out. The first is record retention, which is the weakest in the country: "it is recommended that records be kept for a total of four years". Recommended, not required, and four years rather than the five used in British Columbia, Yukon, Ontario, Alberta, Manitoba, Prince Edward Island, Nova Scotia, New Brunswick, Newfoundland and Labrador and Bermuda. It is the only Canadian jurisdiction we have found that does not mandate retention at all.

The second is the fee schedule, which is published in full where almost every other regulator publishes none. A continuing development deficiency draws a $300 non-compliance fee plus a plan of action or exemption request within sixty days, with only one plan allowed per three-year cycle. A declaration filed between 1 and 30 April draws $100; between 1 and 31 May a further $400, making $500. After 31 May the member faces $500 in late fees plus a $500 reinstatement fee, a $500 non-reporting fee, and automatic suspension under the bylaws. Failure to submit or complete a plan of action brings suspension; failure to respond to an audit may do the same.

Audits are conducted on a sample basis for both the annual and the three-year period, with no rate published — but members who have filed a plan of action are audited automatically the following year.

Bermuda's by-laws set no hours, and charge by the month

Bermuda is structurally the most interesting of the three. Its continuing development obligation sits in the Chartered Professional Accountants of Bermuda By-Laws 2006, a statutory instrument — but the by-laws delegate the figures rather than setting them. By-law 60 requires members to complete "the minimum continuing professional development ("CPD") as determined by CPA Board", reporting "on or before the last day of March in every year", and permits the board or a committee to "review or audit individual CPD reports".

The only hours figures in the statutory instrument are a spent transitional provision from 2006. There is no ethics requirement and no retention period in the by-laws at all.

We also checked the 2019 amendment instrument, made on 18 October 2019 with an operative date of 21 October 2019, because an unopened amendment is a reason not to rely on a consolidated text. It touches exactly one provision in the continuing development block: by-law 60(1), replaced to read that "every CPA Member and CPA Bermuda Only Member shall complete the minimum continuing professional development ("CPD") as determined by CPA Board unless such member is exempt" — a consequence of the new membership classes the same instrument introduced. By-laws 59 and 61 to 65 are not amended. So the $50 per month charge, the three-month suspension trigger and the reporting date of the last day of March all stand as in the 2006 text.

What makes Bermuda distinctive is by-law 64, which carries the only per-month statutory charge we have found anywhere in this programme. Failure to report "shall be reported to CPA Board or a professional conduct committee which may levy a charge of $50 per month". Suspension follows "within three months of the date on which such member's CPD report was due to be filed", with reinstatement on paying a prescribed fee, then possible termination, and a terminated member entitled to apply for re-admission.

The figures the board has actually determined are in the CPA Bermuda continuing professional development policy, updated August 2024: 20 hours reported annually with at least 10 verifiable; 120 hours in every rolling three-year calendar period with 60 verifiable; and a minimum of four hours of verifiable ethics in each rolling three-year period. Retention is a minimum of five years. The compliance report is due annually on 31 March. Members selected for audit must produce evidence of verifiable activity and, in the policy's own words, "will never be asked for evidence of unverifiable CPD".

So Bermuda's ethics hours exist by policy, not by by-law — another entry in the pattern where the same four-hour requirement sits in a different kind of instrument in every jurisdiction.

Manitoba's consequences, which are in the bylaws rather than the policy

We previously could not establish Manitoba's non-compliance ladder. The reason turns out to be that it is not in the continuing development policy, which is silent on the subject. The policy also has no section numbers — it uses named headings only — and states no effective date, carrying only "Updated March 23, 2026".

The consequences are in Bylaw 702. Incomplete continuing development may be reported to the Complaints Investigation Committee. If the report is not filed within two months after the board's reporting date, "the member shall be suspended from membership", with the suspension ending on filing the approved compliance report with the prescribed reinstatement fee. If it is still not filed within two months of suspension, "the person's membership shall be terminated and the Registration Committee shall be informed", with readmission available on filing the report with a readmission fee on board terms.

Record retention is 60 months in the policy and five years in Bylaw 705, which agree. Manitoba's own frequently asked questions do not: two answers give 60 months and a third gives 36. The page does not reconcile them and states that the governing documents prevail, so five years is the figure. Also worth knowing that continuing development reporting gates fee payment in Manitoba — the report and declaration must be submitted before the membership fee invoice can be accessed.

Prince Edward Island requires four ethics hours its own regulations never mention

This is the finding that corrects an inference we were careful not to make. PEI's binding General Regulations, made as an Executive Council order, set 20 hours a year with 10 objectively verifiable and 120 per three-year period with 60 verifiable, and contain no ethics requirement whatsoever. We said so, and said we could not establish whether CPA PEI imposed ethics hours administratively.

It does. The board's published continuing development policy requires a minimum of 120 hours every three-year rolling period which "shall include 4 hours of verifiable learning in professional ethics", confirmed independently on the member guide page. So the regulations alone understate a PEI member's obligations, and anyone reading only the Executive Council order would conclude there was no ethics requirement.

Two more PEI points now settled. The three-year period is rolling, in the policy's own words, not fixed — which the regulations left open by referring to "each three-year period specified by the Board". And record retention is five years from the date of reporting. Audits run "on a risk adjusted basis", randomly sampling member reporting, with no rate published. Non-compliance brings a notice warning that the member "will be fined and/or suspended", then a follow-up letter if documentation is not provided within thirty days; no fine amounts or suspension durations are published.

One conflict we are flagging rather than resolving: the board policy gives the reporting deadline as "on or before May 31 of every year", through membership renewal, corroborated by the member guide. The bylaws point to 31 January. The board's published operative deadline is 31 May, and we would not publish 31 January for PEI without resolving the discrepancy — which matters, because the deadline is the dimension that catches Canadian CPAs out.

And one thing that remains a dead end

CPA Ontario's Regulation 7-2 records that it was "amended on November 1, 2026" and states no effective date for that amendment. We have now looked three separate times. The "Updates to Regulation 7-2" page is still stamped October 2021 and describes only the 2021 amendment. The regulations index lists the regulation with no amendment date, no effective date and no document link. There is no news item, no member communication and no council minute.

So a binding regulation governing every Ontario CPA's continuing development obligation was amended a week ago, and nothing published says what changed or when it takes effect. We are recording that as an unresolved fact rather than guessing at it, and we will revisit it when CPA Ontario publishes something.

The Northwest Territories and Nunavut requirements and fee schedule are published at CPA NWT/NU's own policy page.