Germany CPD: The 40 Hours That Are Not Quite a Requirement

Germany’s continuing education rules for accountants reward careful reading, because the most-quoted figure is not quite a requirement and the professions that look similar are treated very differently. The headline is 40 hours a year for Wirtschaftsprüfer — but the word the by-law uses is soll, not muss, and only half of it is a hard floor. For Steuerberater, meanwhile, there is no number at all.

The statute contains one sentence and no figure

Germany transposed the EU continuing-education obligation about as sparingly as it could. The Wirtschaftsprüferordnung (WPO), at § 43 Abs. 2 Satz 4, says this and nothing more:

Sie sind verpflichtet, sich fortzubilden.

They are obliged to undertake continuing education. That is the entire statutory requirement. No hours, no cycle, no subject split, no deadline. The EU directive behind it sets no number either, so at statute level Germany has an obligation with nothing attached to it.

The numbers live in a chamber by-law

The figures come from the Berufssatzung für Wirtschaftsprüfer/vereidigte Buchprüfer (BS WP/vBP), at § 5 “Fachliche Fortbildung”. The by-law was enacted on 21 June 2016 and came into force on 23 September 2016, under the rule-making power in § 57 Abs. 3 Satz 2 WPO. It has been amended several times since — in December 2019, June 2022, June 2024 and most recently in November 2024, though that last amendment concerned § 16 rather than the training provision.

Anyone looking this up should go to the Berufssatzung, not the WPO. It is a common wrong turn.

40 hours “soll”, 20 hours “müssen” — the distinction that matters

§ 5 Abs. 5 opens:

Die Fortbildung soll einen Umfang von 40 Stunden jährlich nicht unterschreiten.

Continuing education should not fall below 40 hours annually. In German legal drafting, soll signals a target or expectation rather than an absolute command; muss would be the hard form.

The next sentence changes register. Of those hours, 20 must consist of the formal measures set out in § 5 Abs. 2, and those must be documented by type and subject for evidential purposes. That is a müssen — a genuine floor.

So the honest statement of the German position is: 40 hours a year as a target, of which at least 20 hours must be formal, documented measures. The remaining 20 may be Selbststudium, which § 5 Abs. 3 says includes reading professional literature. A great many summaries report a flat “40 hours mandatory”, which overstates the first number and ignores the structure underneath it.

What counts as a formal measure

Under § 5 Abs. 2: lectures, seminars, discussion groups and similar events, whether in-house or external. IT-based courses including e-learning and web-based training count only if attendance duration can be evidenced — so an unmonitored self-paced module does not qualify as structured learning. Treated as equivalent are writing scholarly technical publications, serving on internal or external expert bodies, and university teaching.

Subject matter: “to an appropriate extent”

§ 5 Abs. 4 Satz 3 requires that, for members who perform statutory audits, the training must relate to audit activity in angemessenem Umfang — to an appropriate extent. There is no number. § 5 Abs. 4 also requires training to focus on the member’s actual or intended area of practice.

There is no ethics quota in hours. § 5 Abs. 1 states that the purpose includes keeping understanding of professional duties at a sufficiently high level, but attaches no figure to it.

What Germany does not have

Two absences are worth stating plainly, because their absence is itself the answer:

• No annual declaration deadline was found for WP/vBP. There is a documentation duty under § 5 Abs. 5 “für Nachweiszwecke” — for evidential purposes — evidently tested on request and during quality control, but we located no annual filing to the chamber in the by-law.
• No record-retention period is stated. The documentation duty exists; the by-law puts no number of years on it.

Both are reported here as “none found” rather than “none exists”. Compare France, where statutory auditors face a hard 31 March filing and a six-year retention rule, as our guide to commissaires aux comptes CPD sets out.

Quality control reviewers: a real, numbered, enforced obligation

One group of German auditors does carry a hard figure. Auditors registered as Prüfer für Qualitätskontrolle (PfQK) must complete 24 teaching units of 45 minutes over three years, counted from the day after their registration is announced and spread across the period.

The consequence of not doing so is unusually direct. The chamber states it in two sentences:

Dieser Nachweis ist spätestens alle drei Jahre nach der Registrierung zu führen.

Wird der Nachweis nicht geführt, ist die Registrierung als Prüfer für Qualitätskontrolle zu widerrufen.

Evidence must be produced at least every three years after registration, and if it is not, the registration is revoked. The basis is § 57a Abs. 3a Satz 2 Nr. 4 WPO together with the Satzung für Qualitätskontrolle. The obligation was extended to all registered PfQK, including those not currently performing quality controls, when the audit oversight reform act took effect.

So Germany’s one unambiguous CPD number with an unambiguous sanction applies to a narrow specialist population — not to auditors generally.

Steuerberater: a duty with no quantity

German tax advisers are in a similar position to French experts-comptables. The Steuerberatungsgesetz (StBerG) at § 57 Abs. 2a says:

Steuerberater und Steuerbevollmächtigte sind verpflichtet, sich fortzubilden.

No hours. The chamber by-law adds no figure either: the Berufsordnung der Bundessteuerberaterkammer (BOStB) at § 4 Abs. 3 requires training to the extent necessary to secure and develop the expertise their professional activity requires. No hours, no documentation duty, no retention period.

If you write about German tax advisers, the honest line is: a statutory duty with no quantified requirement. Our guide to the equivalent position in France covers the same pattern in another jurisdiction.

The one German tax-side number

Holders of a Fachberater specialist designation do face a figure, under § 9 of the Fachberaterordnung:

Die Gesamtdauer der Fortbildung darf zehn Zeitstunden nicht unterschreiten.

Dies ist der Steuerberaterkammer unaufgefordert bis zum 31. März des Folgejahres nachzuweisen.

At least 10 hours per calendar year, with proof to the regional chamber unprompted, by 31 March of the following year. This is the only German CPD figure we could verify with a hard filing deadline attached, and it applies only to specialist-designation holders.

Sustainability assurance: proposals, not law — and they conflict

This is the part most likely to be reported wrongly, so the status matters more than the numbers.

As at 23 March 2026, Germany’s CSRD transposition act was not in force. The government draft had reached the Bundesrat as BR-Drucksache 435/25, dated 5 September 2025. Registration as a sustainability auditor could only be applied for once the act was in force, and the chamber said it could not predict when that would be. The relevant provisions are cited by the chamber itself with the suffix denoting a government draft.

Two training figures were circulating, and they did not agree. The draft’s explanatory memorandum suggested at least 40 hours of special training; the chamber’s own board proposed 32 hours in structured form for the transitional route, with no self-study permitted. A further by-law provision on sustainability training was in consultation as at March 2026 with no hours and no effective date stated.

Neither 32 nor 40 was law at the last date we could verify. Treat both as proposals. Germany is the laggard among the larger Member States here, and that is itself the story — Italy had transposed and set 25 credits a year by 2024, and France had set 20 hours a year.

Frequently asked questions

How many CPD hours does a German Wirtschaftsprüfer need? The by-law says training should not fall below 40 hours a year, of which at least 20 must be formal, documented measures. The 40 is a target; the 20 is a floor.

Is there an hours requirement for Steuerberater? No. The statutory duty exists with no quantity attached. Only Fachberater designation holders face a figure, at 10 hours a year.

Does Germany require an annual CPD declaration? None was found for WP/vBP. Fachberater must file proof by 31 March of the following year.

What happens if a quality control reviewer misses the requirement? The registration as Prüfer für Qualitätskontrolle is revoked.

Study with Learnsignal

A “soll” target with a “müssen” core inside it is exactly the kind of structure that gets flattened in translation, and the 20 structured hours are the part that has to be evidenced. Our CPD courses are certificated and documented by type and subject, which is what the by-law asks for. The WPO is published at Gesetze im Internet.