CPD With Two Memberships: Do You Have to Do It Twice?

Hold two accountancy memberships and the obvious worry is that you owe two lots of CPD. Usually you do not — but “usually” is doing a lot of work in that sentence. There are three quite different models in use, and under one of them the obligations genuinely do stack, in full, with no offset.

Model 1: recognition — satisfy one, satisfy both

ACCA is the most generous. Where you are also a member of another IFAC member body and follow their programme:

You will remain eligible to meet the ACCA CPD requirement through following the IFAC body route

And, notably:

ACCA will respect any amendments, variations or waivers your other IFAC member body may decide to make.

So a waiver granted by your other body carries across. That is unusually accommodating, and it means the practical question is which body’s regime suits you better.

HKICPA operates a formal version of the same idea, limited to a named group. Effective 1 December 2023, the CPD compliance requirements of the six member bodies of the Global Accounting Alliance are recognised, so that members belonging to one or more of them:

need only fulfil the CPD requirements of one of those GAA member bodies and, in so doing, shall be deemed to satisfy HKICPA’s CPD requirements.

Three conditions attach, and all three matter:

• You are expected to choose which member body’s CPD requirements to comply with for a full CPD reporting year — not to mix and match within a year.
• You must still file. Members relying on another GAA body’s system are still required to complete the HKICPA annual declaration of CPD compliance. Recognition removes the hours obligation, not the declaration.
• It does not apply to everyone. Recognition operates except for Practising Certificate (PC) or Specialist Designation (SD) holders or Responsible Persons of registered Public Interest Entity auditor (RP). HKICPA states separately that practising-certificate holders who belong to GAA institutes are still required to fulfill the HKICPA’s CPD requirements.

That carve-out is the pattern to watch for generally: recognition tends to stop at the regulated edge of the profession. The closer you are to signing audit opinions, the less likely another body’s compliance will be accepted in place of your own.

Model 2: concession on application — ask, don’t assume

Accounting Technicians Ireland answers the question directly. Asked by a member of CPA, CIMA, ACCA or Chartered Accountants Ireland whether they are exempt from ATI CPD:

In the case of dual membership members may apply for a CPD concession on submission of evidence of CPD compliance/Professional membership from the other professional body to the CPD Programme Manager.

Read that carefully: “may apply for a concession” is not an exemption. It requires an application, evidence, and a decision by a named person. A member who simply assumes their larger body’s compliance covers the smaller one has not complied — they have failed to apply.

ICAP Pakistan handles it through the declaration itself, directing members to declare that they have met the requirement, mark the hours in the non-reported column, and keep a ready reference of the activities undertaken that could be asked for.

Model 3: stacking — both, in full, no offset

Italy is the clearest case in Europe, and it catches a lot of people because most Italian dottori commercialisti are also revisori legali.

The professional body’s regime is triennial. The statutory auditors’ register, administered by a different ministry, is annual — 20 credits every year, 60 across three. These are additive, not alternative.

And the new professional regulation says so explicitly at the sharpest possible point: its full exemption for members who turn 65 during the triennium covers the professional body’s own training and does not extend to training needed to join or remain on external registers such as the auditors’ register.

So a 66-year-old holding both titles is fully exempt under one regime and owes the complete annual obligation under the other — which also has no derogations, exemptions or waivers of any kind. See our guides to the revisori legali regime and the commercialisti regime.

The French exception worth knowing

France produces a happier answer for dual-qualified practitioners. Many experts-comptables are also commissaires aux comptes, where the obligation is a numbered 120 hours over three years in the Code de commerce, while the expert-comptable benchmark is a professional-body recommendation of the same figure.

The same hours may be counted against both. A dual-qualified practitioner who meets the statutory auditor requirement has, by the same activity, met the recommended benchmark — they do not need 240 hours. Our guide to why France sets no CPD hours in law for experts-comptables covers why.

Same designation, different jurisdictions

Holding the same qualification in two places is its own case. CPABC answers it for Canada:

All the provincial bodies in Canada have adopted international CPD standards.

This has brought greater harmonization to the CPD requirements across Canada.

However, there may be differences due to legislation.

If you are a member of more than one provincial CPA body, please be sure to contact the other bodies to ensure that you meet all your CPD requirements.

Harmonised is not identical, and the differences are legislative rather than discretionary. That is consistent with what we found elsewhere: two Canadian provincial bodies reach opposite conclusions on whether a retired member on a charity board needs CPD at all.

A note on evidence

HKICPA makes a point that applies to every model above. Asked how to get attendance records for another body’s purposes, it advises members to ascertain and follow the requirements of those other bodies, and warns that its own system’s records may not be sufficient evidence.

So even where the hours are recognised, the evidence may need to be produced in the other body’s format. Our guide to CPD record examples sets out the fields that travel best.

What to do

• Find out which model each of your bodies uses. Recognition, concession, or stacking — they behave completely differently.
• If it is a concession, apply. Assuming an exemption you never requested is the commonest failure here.
• Check for a regulated carve-out. Practising certificates, specialist designations and audit roles are routinely excluded from recognition.
• File every declaration anyway. Recognition of hours almost never removes the duty to declare.
• Pick one regime per year where you are told to, rather than mixing within a reporting year.

Frequently asked questions

Do I have to do CPD twice if I hold two memberships? Usually not, but it depends on the model. ACCA and HKICPA recognise another body’s compliance; ATI requires an application for a concession; Italy stacks the obligations in full.

Does a waiver from one body carry to the other? With ACCA, yes — it states it will respect amendments, variations or waivers made by your other IFAC body.

Can I still rely on recognition if I hold a practising certificate? Often not. HKICPA excludes practising certificate and specialist designation holders and PIE auditor responsible persons.

Do I still have to make a declaration? Yes. HKICPA requires the annual declaration even from members complying through another GAA body.

I am dual-qualified in France. Do I need 240 hours? No. The same hours count toward both obligations.

One programme, evidence for both, with Learnsignal

Where recognition applies, the useful thing is CPD documented well enough to satisfy whichever body asks. Our certificated courses record activity, date, duration and subject in a form that transfers between regimes. See also what actually happens if you do not comply. ACCA’s member CPD guidance is published at accaglobal.com.