What Happens at an HPCSA CPD Audit, and What the Sanction Is

Most writing about South African CPD stops at the number of units. What happens if you are short of them is a separate question with a separate answer, and the answer is not the one most practitioners assume. You are not erased from the register. You are suspended from practice until you produce proof.

CPD is a condition of keeping registration

Board Notice 701 of 2024, made under section 26 of the Health Professions Act 56 of 1974, states it directly. Rule 3 provides that CPD compliance "shall be a prerequisite for such practitioner to retain his or her registration in terms of" the Act. The instrument is published by the South African government.

Note the wording: a prerequisite to retain registration, not to obtain it. The obligation is continuous, and the same Board Notice sets the accrual at 30 CEUs over twelve months for full-scope registers, with five in ethics, human rights and health law, and a twelve-month shelf life on each unit.

Twenty-one days, and where that figure comes from

Practitioners selected for audit "should submit the information requested to the CPD section within 21 days", according to HPCSA's CPD Guidelines, published by the Council and dated November 2021.

Twenty-one days is not long to assemble a year of evidence retrospectively, which is the practical argument for keeping records as you go rather than at the point of request.

One important caveat about the source. Neither Board Notice 29 of 2007 nor Board Notice 701 of 2024 contains an audit provision at all. The 21-day window exists in the Guidelines, not in the rules. So it is the Council's stated administrative practice rather than a provision of subordinate legislation — worth knowing if you are ever arguing about it.

There is no published selection rate, and we are not inventing one

We looked for it. Neither the rules nor the Guidelines describe how practitioners are selected for audit, and no percentage appears in any instrument we could read.

That matters because figures do circulate. For comparison, the UK's HCPC publishes its rate openly — it audits a random 2.5% of registrants at renewal — and New Zealand's Nursing Council publishes five percent. HPCSA publishes neither. If you see a South African audit percentage quoted, ask for the instrument it comes from.

The sanction is suspension, not erasure

This is the correction most worth making, because it runs in both directions and people get it wrong either way.

Board Notice 29 of 2007, Rule 9(d), provides for "suspension, for a specified period, from practice as may be determined by the board", alongside three alternatives the board may impose: supervised practice, a remedial programme, or an examination. The 2007 rules are archived on the Law Library's legislation collection.

The Guidelines put the practical version more plainly still: "suspension from the register until submission of proof of compliance with the CPD requirements is submitted."

Read that carefully. The suspension is conditional and self-terminating — it lifts when you produce the proof. It is a lock rather than a punishment.

And erasure is not a CPD consequence. The Guidelines mention erasure only in a glossary entry about restoration after it, and the 2007 rules do not mention erasure at all. Anyone telling a South African practitioner that a CPD shortfall gets them struck off is overstating it. Anyone telling them nothing happens is understating it, because suspension from practice is an immediate income event.

Deferment and exemption do exist

Two routes out, both in Board Notice 701 of 2024.

Rule 7 provides that "Deferment of compliance with the requirements of continuing professional development" for any specific period "may be granted to individual practitioners by the Board on application", and "subject to such conditions as the committee may determine." Deferment is applied for, not assumed, and conditions can attach.

Rule 8 exempts practitioners in community service, and registrars and interns: a practitioner "registered as a registrar or performing internship training is not required to comply" with the CPD requirements "whilst being so registered." That is an automatic exemption for the duration of the training registration, not something to apply for.

How long to keep the evidence

Practitioners "shall keep these for at least two years". On the provider side, the attendance register "must be held by the presenting organisation or institution for three years following the activity".

Note the mismatch: providers retain for three years, practitioners for two. If you are reconstructing a record older than your own retention period, the provider may still have it.

One live qualification

A notice dated 20 April 2026 from HPCSA Corporate Affairs states that CPD "will not be a mandatory requirement when renewing annual registration" this year, while practitioners "are still required to maintain their CPD compliance to ensure continuation of registration."

We are flagging that it appears on hpcsa-blogs.co.za rather than hpcsa.co.za and that we could not corroborate it on the Council's main site. The sensible reading is that the renewal counter has been relaxed for one year while the underlying rules and the suspension mechanism above are untouched. Check before relying on it.

For providers and employers

The accreditation side of this — per-activity approval in advance, twelve-month accreditation terms, and online accreditable only at Levels 1 to 2 — is in our guide to who can sell CPD to a South African health professional. Pharmacists sit under a different model again, filing six portfolio entries, in SAPC pharmacist CPD, and attorneys have no CPD obligation at all, in South African attorneys have no mandatory CPD.

This article quotes the Board Notices and HPCSA Guidelines as published and declines to state an audit selection rate, which is not published. Verify with HPCSA before relying on any of it.