CPD Review Outcomes: What the Published Figures Actually Show

Most writing about CPD compliance describes the rules. Very little describes what actually happens when bodies apply them — who gets reviewed, how many fail, and what they fail for. The figures that are published are more interesting than the rules, and they point somewhere counter-intuitive.

The headline figure

ACCA removed 796 members for CPD default in a recent year. Every one of those removals was for paperwork or non-cooperation. Not one was for doing too little CPD.

That single data point reframes the whole subject. The enforcement mechanism is not auditing the quantity of your learning. It is auditing whether you responded, declared, and could produce a record.

And the figure that explains it

Of ACCA’s 2024 declarations, 46.26% were made by the 1 January deadline. Three months later the figure was 89.35%.

So more than half the membership missed the deadline, and the large majority of those then complied late. A declaration system where the on-time rate is under 50% is not primarily catching people who have not learned anything. It is catching people who have not filed.

Put the two figures together and the conclusion is uncomfortable: a member who completes no CPD but declares on time is in a better position than one who completes their CPD and does not respond to correspondence. That is not how most people imagine the risk.

How members actually get selected

There are four distinct selection models in use, and which one applies to you changes how you should prepare:

• Annual sample. ICAS runs a CPD sample and publishes guidance answering “Why have I been selected for the CPD sample?” — which tells you selection anxiety is common enough to need its own page.
• Random selection. Austria’s accounting-professions authority selects people at random for the preceding calendar year and requires proof within two months. You cannot predict it, so the only workable posture is to be ready every year.
• Universal declaration with follow-up. ACCA and most bodies require a declaration from everyone, then investigate the non-responders.
• Verification on request only. Poland has no routine annual filing at all — documentation is produced within 30 days of a request. Czechia goes further and excuses you from filing entirely if every hour came through chamber-organised events, because the chamber already holds the data.

Uganda’s institute fields a question that reveals how this feels from the inside: “Can I be sampled even when I have submitted my CPD return?” Submitting is not immunity.

What reviewers actually look at

Where bodies describe their review process, the emphasis is consistently on evidence quality rather than hours:

• CPA Australia states that presentation slides, registration emails and general course materials are not sufficient for verifying ethics CPD. The commonest things members keep are the things that do not count.
• Uganda’s institute answers “does the accumulation of 40 CPD hours make me compliant?” with a qualified no.
• South Africa’s audit regulator asks what it means for your work if a development gap remains after you completed the activity — whether you need to bring in a specialist or restaff. Completion is not the test; competence is.
• Spain forfeits self-study hours entirely if the member fails the assessment.

Our guide to CPD record examples sets out the fields that survive this kind of scrutiny.

Is there a right to fix it?

This is a genuine anxiety axis and bodies answer it differently. SAICA publishes two questions on it: whether a member can send a reflective learning plan in for review before being monitored, and whether, if the plan is wrong when monitored, there will be an opportunity to correct it before any penalty. The existence of those questions tells you members are worried about being judged on a format they were never shown.

Elsewhere the latitude is explicit:

• Poland may allow completion up to two years late on a documented and justified request.
• Spain treats a late complementary declaration as a minor infraction that prescribes after one year.
• ICAS fields a request for an extension on the grounds of being on annual leave during the submission window.
• Portugal offers none of this: once the filing deadline passes without compliance, the regulation imposes an automatic bar on practising.

What the sanctions actually are, where published

• Portugal — automatic bar on practising for certified accountants.
• Germany — for quality control reviewers, the registration is to be revoked if evidence is not produced. Mandatory, not discretionary.
• Switzerland — the fiduciary association’s sections may fine CHF 2,000 to 10,000 per member per control period, or expel.
• Austria — up to €5,000 for failing to provide proof two years running.
• CIMA — a Fixed Penalty Scheme and a publicly available record of non-compliant members, despite prescribing no hours at all. We are not printing the amounts, because the only text we obtained for that regulation was a reconstruction rather than CIMA’s published wording.
• Czechia — the provision creating the obligation states no sanction. The Act refers elsewhere to disciplinary and administrative penalties, but in the text we read neither is tied specifically to CPD. We report that as what we found, not as a conclusion that nothing follows.

Full detail in our guide to CPD penalties.

One figure worth not misreading

France’s audit regulator reported that ethics, independence and organisation made up 9.66% of declared training activity in 2023. That is a statistic about what auditors chose to do. France sets no ethics quota at all, and the figure is occasionally quoted as though it were a requirement. It is not.

It is, however, a useful benchmark: roughly one hour in ten, freely chosen, in a jurisdiction that compels none.

What to take from the data

Treat the declaration as the deliverable. The published removal figures say the filing is what fails, not the learning.

Assume you could be selected this year. Random selection and annual sampling both mean preparedness cannot be timed.

Keep evidence of the right kind. Certificates naming activity and duration, and attendance records. Not slides, not registration emails.

Record unresolved gaps honestly. At least one regulator treats a remaining competence gap as a live question about resourcing, not as a failure to conceal.

Frequently asked questions

How many accountants actually get removed over CPD? ACCA reported 796 removals for CPD default in a recent year, all for paperwork or non-cooperation.

Do most members declare on time? No. ACCA’s 2024 on-time rate was 46.26%, reaching 89.35% three months after the deadline.

How am I chosen for review? Four models are in use: annual sample, random selection, universal declaration with follow-up, and verification only on request.

Does submitting my return protect me from being sampled? No. At least one institute answers that question explicitly.

Can I correct a defective record before being penalised? It varies. Poland allows completion up to two years late on request; Portugal imposes an automatic practice bar with no equivalent latitude.

Be the member who files on time, with Learnsignal

If the published data says the risk is administrative, the useful product is training that documents itself. Our certificated CPD courses record the activity, date, duration and subject in the form these regimes ask you to declare. See also what changes if you stop practising. ACCA publishes its membership regulations and compliance reporting at accaglobal.com.