ICAP’s CPD Rule Is a Council Directive, and Records Need Keeping Only One Year

ICAP's continuing development requirement looks familiar — 120 hours over a rolling three years, 60 of them verifiable, at least 20 a year. The interesting parts are where the rule comes from, how short the record-keeping period is, and the fact that an engagement partner can comply by meeting an international standard's learning outcomes instead of doing a fixed number of hours.

A council directive, with a statutory misconduct hook

The Chartered Accountants Ordinance 1961 does not mention continuing development or professional education anywhere. What it does is build a chain.

Section 15(2)(i) gives the Council the function of "the regulation and maintenance of the status and standard of professional qualifications of the members of the Institute". Section 27(2)(kk) provides that by-laws may provide for "the issue of directives to the members of the Institute on professional matter". And Schedule I, Part 4, item (3) makes it professional misconduct for any member, whether in practice or not, who "does not comply with any of the directives issued or pronouncements made by the Council or any of its Standing Committees".

So a directive carries the obligation, and breach of a directive is misconduct. Section 20D(1) then sets the consequences: the Council may reprimand or warn, impose a penalty "not exceeding one thousand rupees", or remove the member's name from the register "for a period not exceeding five years", with longer or permanent removal reserved to the High Court.

The directive is Directive 8.01 (Revised 2022), "effective from 05 January, 2023". It is described by ICAP as revised for full compliance with the international continuing development standard for both practising and non-practising members. Worth noting: neither the directive nor the page listing it cites the Ordinance or the by-laws as its basis, and we could not locate a continuing development provision in the by-laws themselves. The chain above is assembled from the Ordinance, not stated in the instrument.

The hours, and a carry-forward rule most bodies do not have

Directive 8.01 requires members to "complete at least 120 hours or equivalent learning units" in each rolling three-year period, "of which 60 hours or equivalent learning units should be verifiable", and to "complete at least 20 hours or equivalent learning units in each year".

ICAP's vocabulary is verifiable and non-verifiable. The directive never uses the words structured or unstructured, and those are not interchangeable concepts — so a reader mapping ICAP's rule onto a structured-hours regime will get it wrong.

The caps are specific. Non-verifiable activity, where the member cannot prove the learning took place, is capped at 30 hours per rolling period. On-job learning counts at half the hours spent, capped at 60 credit hours per three-year period. Self-development and virtual learning count at actual hours, up to 120 in a rolling period.

Then the unusual bit. ICAP allows a shortfall to be carried forward: "only 30 hours out of the total shortfall hours will be carried forward to the next rolling period", and 30 excess hours from the final year carry forward as well. Most bodies allow neither. Carrying a deficit into the next cycle, within a capped amount, is a genuinely different compliance design — it softens the cliff edge that a fixed cycle normally creates.

The cycle runs 1 July to 30 June. The only cycle ICAP states on its published pages is 1 July 2021 to 30 June 2024, which has closed. The successor period is not published, and although the next three years follow arithmetically, we are not going to assert dates ICAP has not printed.

Ethics applies to engagement partners only — and they can choose IES 8 instead

ICAP imposes no ethics requirement on its general membership. Ethics appears only in the engagement partner obligation, and there as one of several eligible areas rather than as a quota.

An engagement partner must either complete "at least 30 hours in each rolling period" across a list of areas — audit, financial reporting and accounting, governance and risk, ethics, corporate laws, and the international auditing and reporting standards — or meet the learning outcomes set out in the directive's own Annexure B, Table A, which reproduces IES 8's framework.

That second route is worth dwelling on. It is the cleanest example we have found of a national body offering compliance with IES 8's outcome-based framework as a direct alternative to counting hours — which is what IES 8 was designed for, since it contains no hours figure at all. Most regulators that cite IES 8 bolt it onto an hours requirement. ICAP lets the partner pick.

The practical consequence is that no standalone ethics-hours figure exists for ICAP. Ethics is one of six eligible areas inside a 30-hour block that is itself optional if the partner takes the outcomes route. Anyone publishing a Pakistani ethics hours number is inventing it.

One year of record retention

Verifiable activity "must be supported by documentary evidences", kept "for one year after the close of rolling period". Evidence for a career-break waiver must be kept three years.

One year is the shortest retention period we have found anywhere outside Quebec's twelve months. Kenya's ICPAK requires five years, as do most Canadian regulators, the IPA in Australia, and most US state boards, which run from four years to six. A Pakistani member's documents can be discarded a year after the cycle closes.

That interacts with the audit design. The directive says "sample audit will be carried out at the end of three-year rolling period", with selected members notified by email and given a submission deadline. So the audit happens at the end of the cycle and the retention obligation runs for a year beyond it — which is coherent, but leaves no margin for a later query. No sample rate and no compliance statistics are published.

The recording split is worth knowing too: ICAP's CPD Directorate records only Institute-organised activities and committee participation. Everything else is maintained by the member, with attendance sheets due from committees within two weeks of an activity and self-development items communicated within two weeks.

Non-compliance, and a 120-day cure period

At the end of each year and each rolling period, a member who has fallen short signs a non-compliance declaration containing "a firm commitment to make up the deficit within 120 days". The shortfall carry-forward is then limited to 30 hours into the next period. Beyond that, "the CPD Committee may recommend appropriate sanctions to the Council", and the Ordinance route described above becomes available.

No annual declaration date is published. ICAP requires an annual online declaration and states no calendar deadline for it in either the directive or its frequently asked questions, which is a notable gap given that the declaration is the compliance event.

Exemptions, with conditions attached

The directive does not apply to members who are ill or incapacitated — but the practice licence or membership status must be surrendered first, which makes this a withdrawal from practice rather than a pause. It also excludes members retired from whole-time business, lifetime members, and members holding public office during their term, naming ministers, senators and members of the national and provincial assemblies.

Career breaks are available but deliberately temporary: "It is not perpetual and Member has to apply every year." The CPD Committee may also grant an exemption it considers justifiable, with reasons recorded. The directive is explicit on the general point: "the exemption is only based for the period mentioned, it cannot be given on perpetual basis."

ICAP has been an IFAC member since 1977. The directive is published at ICAP's own site.