France Sets No CPD Hours in Law for Experts-Comptables

Search for the CPD requirement for a French expert-comptable and you will be told, repeatedly and confidently, that it is 120 hours over three years with a minimum of 20 hours a year. Those figures are real. They are not law. No French legal instrument sets any number of CPD hours for experts-comptables. The 120 and the 20 are a recommendation of the profession’s own governing body, and understanding that distinction changes how the obligation is actually enforced.

The legal duty exists. It is unquantified.

The obligation itself is genuine and statutory. Décret n° 2012-432 du 30 mars 2012, which contains the Code de déontologie for accounting professionals, requires members at article 145, 1°:

1° A compléter et mettre à jour régulièrement leur culture professionnelle et leurs connaissances générales ;

To complete and regularly update their professional knowledge and general knowledge. There is no figure anywhere in it — no hours, no cycle, no verifiable proportion.

For experts-comptables working in business rather than practice, Ordonnance n° 45-2138, article 13-IV-3° imposes a parallel duty to regularly update professional and general knowledge. Again with no number.

A note for anyone checking this themselves: article 148 of the same décret is frequently miscited as the CPD provision. It is not. It concerns the competence of staff to whom work is delegated, and it contains no hours figure either.

The règlement intérieur does not supply a number either

The obvious next place to look is the profession’s internal rules, approved by ministerial arrêté. The Arrêté du 6 mars 2024 portant agrément du règlement intérieur de l’ordre des experts-comptables does contain substantial training provisions — Titre V, running from article 500 to article 567.

But those provisions govern the stage, the pre-qualification traineeship, not post-qualification continuing development. The Ordre’s own compiled regulation of the profession contains no CPD hours provision. We looked specifically, in the décret, the Code de déontologie and the règlement intérieur, and there is no number in any of them.

So where do 120 and 20 come from?

From the Ordre itself, as a recommendation. The Conseil national’s own national site states that it recommends devoting at least 120 hours per rolling three-year period and at least 20 hours a year. It also states how compliance is tested: l’obligation de formation continue est constatée lors des contrôles de qualité — the continuing training obligation is observed during quality control reviews.

The regional councils are blunter still. Two of them state expressly that the figures ne figurent pas — do not appear — in the Code de déontologie or in the professional standards, which set principles rather than quantities, and they trace the 120/20 benchmark directly to IFAC’s International Education Standard 7. One regional council calls it, in terms, “une recommandation de l’Institution”.

That lineage is worth pausing on, because IES 7’s own 120 hours is itself an illustration in application material rather than a requirement — a point we set out in our guide to where accountant CPD requirements come from. So the French benchmark is a professional-body recommendation derived from an illustrative figure in an international standard that binds member bodies rather than individuals. Three layers of softness, each one commonly reported as hard law.

What that means in practice

It would be a mistake to conclude the obligation is toothless. It is enforced, just through a different mechanism. Rather than an annual declaration audited against a threshold, the duty under article 145 is assessed during quality control review, where the recommended benchmark supplies the yardstick. An expert-comptable who had done very little would be judged against article 145’s requirement to update knowledge regularly, with 120 hours over three years as the reference point the Ordre has published.

Three practical consequences follow:

• There is no declaration deadline. We found none, in contrast to the hard 31 March filing that applies to statutory auditors.
• There is no prescribed record-retention period. Again in contrast to the six-year rule for auditors.
• There is no ethics minimum. None found in any instrument.

The useful wrinkle: dual-qualified practitioners do not need 240 hours

Many experts-comptables are also commissaires aux comptes, where the obligation is genuinely numbered — 120 hours over three years with 20 a year, set in the Code de commerce, as our guide to commissaires aux comptes CPD explains.

A reasonable worry is that holding both titles means doubling up. It does not. According to the Ordre’s regional guidance, the same hours may be counted against both obligations. A dual-qualified practitioner who meets the statutory auditor requirement has, by the same activity, met the recommended expert-comptable benchmark.

This is a genuinely helpful piece of information and it is not widely stated.

Why the distinction matters beyond France

The French split is a clean illustration of a pattern across Europe: the quantified obligation attaches to the statutory audit perimeter, because that is what the EU directive reaches, while professions outside it carry an unquantified duty. Germany does the same thing with Steuerberater. The EU Statutory Audit Directive sets no hours of its own, which is why national regimes diverge so sharply and why the answer to “what is the requirement?” depends first on which register you are on.

It also matters for anyone writing or relying on cross-border CPD summaries. A table that lists France as “120 hours / 3 years” without distinguishing the two professions is reporting a recommendation as a legal requirement for one of them.

A note on sourcing and its limits

We verified that no hours figure appears in Décret n° 2012-432, in the Code de déontologie articles 141 to 169, or in the règlement intérieur approved in March 2024, and that the Ordre presents 120/20 as its own recommendation traced to IES 7. We did not exhaustively search for a norme professionnelle issued by the Conseil supérieur on the point. So the accurate formulation is the one we have used throughout: France sets no CPD hours in law for experts-comptables, and the 120/20 figure is the Ordre’s recommendation, tested in quality control. That is a narrower claim than “no instrument of any kind exists anywhere”, and it is the one the evidence supports.

Frequently asked questions

Is there a legal CPD requirement for French experts-comptables? Yes, but it is unquantified. Article 145, 1° of Décret n° 2012-432 requires members to complete and regularly update their professional knowledge, with no hours figure.

So the 120 hours is wrong? Not wrong, but mischaracterised when presented as law. It is the Ordre’s published recommendation, assessed during quality control.

Is there a declaration to file? No deadline was found, in contrast to the 31 March filing required of statutory auditors.

I hold both titles — do I need 240 hours? No. The same hours count toward both obligations.

Build a defensible CPD record with Learnsignal

A benchmark tested at quality control is, in practice, a reason to keep better records rather than fewer — because the assessment is qualitative and the evidence is yours to produce. Our CPD courses are structured and certificated, which makes that evidence straightforward. The décret cited here is published on Légifrance.