ICAB’s CPD Duty Contains No Figures, and the Only Published Numbers Are in a Slide Deck

Bangladesh has a binding continuing education duty for chartered accountants and no publicly retrievable statement of what it requires. The bye-law that creates the obligation contains no figures. The only figures we could find sit in a presentation deck from 2019, published by the Institute itself, whose sanctions list stops mid-sentence.

We are setting out what we found, with the sourcing problems attached, because the alternative — repeating numbers as though they were confirmed current rules — is how most writing on this subject goes wrong.

The statute says nothing

The Bangladesh Chartered Accountants Order, 1973, President's Order No. 2 of 1973, contains no continuing development provision. Its nearest provisions concern entry and trainees rather than members: article 4(1)(ii) refers to a person who "has passed such examination and completed such training as may be prescribed", which is qualification, and article 16(2)(b) covers "the regulation of the engagement and training of articled students", which is trainees.

What the Order does supply is the power to make rules. Article 28(1) provides that "the Council may, by notification in the Gazette, make bye-laws for the purpose of carrying out the objects of this Order", and article 28(2)(s) allows bye-laws setting "the rules of professional and other misconduct, and the exercise of disciplinary powers". Article 20 lets the Council remove a member's name from the register on specified grounds.

Bye-law 10 creates the duty and leaves it empty

The obligation sits in the ICAB Bye-laws 1973, as amended up to 31 August 2023, at Part II, Chapter II, bye-law 10, headed "Continuing Professional Education".

Bye-law 10(1): "Every person after becoming a member of the Institute shall undergo Continuing Professional Education". Bye-law 10(2) makes failure "to attain the prescribed standard as stated in clause (1) above" grounds for disciplinary action "as the Council may decide from time to time". Bye-law 10(3) lets the Council grant exemption or relaxation from the prescribed standard. Bye-law 10(4) lets the Council levy fees or charges for the programme.

No hours. No cycle. No split. No subject. The bye-law establishes that there is a standard and that failing it is actionable, and leaves the content entirely to Council decision.

There is also a vocabulary mismatch worth noting, because it affects anyone searching for the rule. The binding instrument says "Continuing Professional Education". The Institute's policy and member portal say "CPD". They are the same obligation under two names.

The figures, and why we are hedging them

The Council's policy is the "Continuing Professional Development Policy 2019", stated to be "made effective from 1st May 2019", with year one running 1 May 2019 to 30 April 2020.

We did not read that policy. What we read is an ICAB-hosted presentation deck summarising it — a slide summary, not the instrument, with text truncated mid-sentence in several places, carrying no policy number, no Council approval date and no citation of the Order or the bye-laws. We looked for the policy document itself and did not find it.

On that basis, the figures in the deck are: all members complete at least 20 CPD hours a year, of which 10 verifiable; and at least 120 hours over a rolling three-year period, of which 60 verifiable. Practising members additionally complete at least 6 hours a year in IFRS, the auditing standards, taxation and corporate laws, of which 3 verifiable.

The deck also sets out a transitional ramp, with cycle totals of 40 hours for 2019-20, 72 for 2020-21 and 120 for 2021-22, and practising-member specialised hours of 6, 18 and 30 across the same years.

So the honest formulation is this: per ICAB's 2019 policy as summarised in ICAB's own 2019 presentation, the requirement is 20 hours a year and 120 over three. Whether the 120 steady state actually took effect, and whether these are the figures in force in 2026, we could not verify. The deck is seven years old, and we found no newer ICAB statement of hours. IFAC's own page confirms that ICAB requires continuing development for members and gives no number at all.

There is also an unresolved internal contradiction in the deck. A slide on Fellowship says compliance is required for "each of the last consecutive five years", which does not sit with the rolling three-year cycle stated elsewhere.

Two axes of classification, not one

ICAB uses verifiable and non-verifiable, and does not use structured or unstructured. But it adds a second axis that few bodies do: specific and non-specific, applying to practising members.

So a member in business needs 10 verifiable and 10 non-verifiable hours a year. A member in practice needs 7 verifiable non-specific, 3 verifiable specific, 7 non-verifiable non-specific and 3 non-verifiable specific. Four buckets rather than two.

Verifiability, per the deck, "depends on the quality of records and evidences maintained", and participation records from ICAB or from permanent member institutes of the international federation count as verifiable evidence.

No ethics requirement at all

Neither bye-law 10 nor the 2019 deck mentions ethics as a mandatory subject. The practising-member mandatory areas are IFRS, the auditing standards, taxation and corporate laws, and ethics is not among them.

That makes Bangladesh unusual. Almost every body we have documented mandates at least some ethics content — two hours a year in Japan and for the CMA, four verifiable hours per cycle across Canada, two structured hours per designation at SAIPA, one hour at ICAEW, seven hours a year under the IPA's new rule. Pakistan's ICAP confines ethics to engagement partners, as we set out separately, but it does name it. We found no ICAB ethics requirement in anything we could read.

What is simply not published

The cycle is anchored to 1 May. Hours from third-party activities must be claimed within six months of being earned, and the completion date determines which period they count toward. Members applying for a certificate of practice must have complied for the immediate past year.

Beyond that: no annual submission or declaration deadline is stated. No record retention period is specified — members must maintain evidence "as far as practicable", with no term attached. No audit, sample-verification process or compliance statistic is published. ICAB launched a CPD portal in 2023, which IFAC notes supports "member participation and monitoring", but how it monitors is not documented on anything we could reach.

The escalation ladder is the starkest gap. The deck's section 14 lists, as disciplinary action for non-compliance: advising the member to recover the shortfall within a specified time; imposing additional requirements during the current or a future period; issuing warnings; and then "suspension of membership for" — at which point the source text cuts off. We do not know the suspension term or whether further steps follow. The exemption list has the same problem: ill or incapacitated so that the member cannot perform normal work; retired from practice or business; and "members who apply for exemptions for any other reason(s) justifiable to", truncated.

Underneath all of it sits bye-law 10(2)'s open formula — disciplinary action "as the Council may decide from time to time" — and bye-law 10(3)'s power to grant exemptions under rules the Council frames. We could not locate those rules.

Why it is this hard to find out

ICAB's website is a JavaScript-rendered application that serves no readable content to automated retrieval. Its CPD pages did not render; the news page announcing the CPD portal returned nothing but a notice that JavaScript must be enabled. Everything above comes from two ICAB-hosted PDF documents: the Members' Hand Book, which carries the bye-laws, and the 2019 presentation.

This is the same shape of problem as Saudi Arabia, where the governing membership rules are not publicly retrievable either. In both cases the requirement plainly exists and is enforceable — ICAB's through bye-law 10(2) and the Order's disciplinary machinery — and in both cases a member cannot read it. Absence of publication is not absence of obligation, and it is worth saying which one you are looking at.

One incidental finding, since it is often misread as a member duty: clause 82(2)(d) of the Members' Hand Book obliges the Technical and Research Committee to "arrange for a minimum of four technical CPE seminars in a calendar year for members on accounting and auditing matters". That is a supply obligation on the Institute, not a requirement on the member.

ICAB has been an IFAC member since 1977 and is assessed as "Sustain" on the standard-setting obligation covering continuing development. The bye-laws are in ICAB's Members' Hand Book.