The 120-Hour CPD Rule Is an Illustration, Not a Requirement

The most quoted number in accountancy continuing development is 120 hours over three years, with 60 verifiable and at least 20 a year. It is usually attributed to IES 7, the international standard. IES 7 does not require it.

The figures appear in the standard's application material as an illustration of what an input-based approach might look like. The standard permits a body to measure continuing development by input, by output, or by a combination — and at least one national regulator has taken the output route to its conclusion and set no hours at all.

Two ways to measure the same obligation

An input-based approach counts what goes in: hours attended, credits earned, units claimed. An output-based approach asks what came out: whether the accountant can demonstrate the competence the work requires.

The substantive duty in IES 7 is about developing and maintaining competence. Hours are a proxy for that, and the standard says so plainly in its own guidance on measurement, warning that input-based approaches do not always measure the learning outcomes or competence developed. The illustration that produced the 120 figure is exactly that — an illustration of one way to run the proxy.

Once you see this, a lot of apparently odd national design makes sense. Bodies are not all implementing the same rule badly. They are choosing different points on a spectrum the standard deliberately leaves open.

The pure output end: no hours at all

The Dutch regulator is the clearest case. Its current rules, in force since 1 January 2026, contain no hours, no units, no credits and no multi-year total. What they require instead is a portfolio: the work the accountant does, the learning objectives that follow from it, the activities undertaken, evidence that they happened, and the outcomes achieved.

Compliance is then judged on whether that portfolio hangs together. The regulator publishes its sampling design — a stratified random sample calibrated so each accountant is assessed on average once every six years, with two assessors and a third where they disagree materially. There is no number for a Dutch accountant to hit, which means there is also nothing to game.

That design has a cost, and it is visible in the retention rule: six years, longer than almost anywhere, because a portfolio has to survive long enough to be assessed. An hours regime can be audited from certificates; an outcome regime has to be audited from the reasoning.

The hybrid: hours, with an output alternative

Pakistan's institute offers the cleanest hybrid we have found. Its engagement partners may either complete at least 30 hours across a list of subject areas, or meet the learning outcomes set out in its own annexure reproducing the international standard for engagement partner competence.

A partner picks one route or the other. That is unusual: most regulators that cite the engagement partner standard bolt it onto an hours requirement rather than offering it as an alternative to one — which is odd, given that the engagement partner standard contains no hours figure at all and is purely outcome-based.

New Zealand's licensed auditors sit in similar territory, with their body describing an output-based education model while the general membership requirement remains expressed in hours.

What "verifiable" is actually doing

Most bodies sit in the middle, and the verifiable quota is where the two philosophies meet. A verifiable hours requirement is still an input measure — it counts hours — but it imports an evidential test that an output approach would recognise. The question is not what you learned but whether a third party can confirm the activity happened.

That is why the vocabulary diverges so sharply once you look at it closely, and why the terms are not interchangeable:

Canada's regulators and most US state boards use verifiable against unverifiable, with an objective-verification test. Malaysia fuses two concepts and demands hours that are structured and verifiable. Singapore runs two parallel regimes, one asking for verifiable hours and the other for structured ones, which are different tests on the same learning. Quebec uses neither — it caps self-study at fifteen hours a year and uses "structured" as its quality concept, so the commonly repeated sixty verifiable hours is simply not a Quebec requirement. South Africa's SAIPA treats structured and verifiable as synonyms and says so. Pakistan's institute never uses the word structured at all. Japan draws no distinction of any kind. And China uses an input method and an output method as its two named categories, which is the spectrum in this article rendered as a classification.

Nine bodies, at least six genuinely different tests. A course that satisfies one may fail another, and there is no published crosswalk between them anywhere.

What this means if you are the one complying

Three practical points.

First, do not reason from the international standard to your own obligation. The standard tells your body what to do; your body's instrument tells you. The 120 figure survives in most places, but the annual floor, the verifiable quota, the cycle shape and the quality test all vary, and the standard requires none of them specifically.

Second, if you hold two memberships, check which measurement philosophy each uses before assuming hours transfer. Hours do not convert into a portfolio and a portfolio does not convert into hours. A Dutch accountant with a foreign membership has to satisfy both tests independently, and neither discharges the other.

Third, where your body uses a verifiable or structured quota, the binding constraint is usually evidence rather than time. The accountant who falls short is more often the one who cannot prove what they did than the one who did too little — which is consistent with what enforcement data shows across this field, where sanctions attach overwhelmingly to declarations and documentation rather than to the quantity of learning.

The standard's own text, including its application material on measurement, is published at IFAC's accountancy education e-tool.