You Cannot Buy 25 Structured CPD Units From One Provider in Kenya

A Kenyan accountant needs 25 structured CPD units a year. ICPAK's category system makes it arithmetically impossible to get them all from one place — including from ICPAK itself. That is not a quirk of interpretation; it falls straight out of the caps.

The requirement, and the split

ICPAK's position is that "A member is expected to earn at least 40 CPD hours in a year or 120 CPD hours in three years", split into 25 structured and 15 unstructured.

The annual and three-year framings are alternatives rather than a single rolling test, and good standing is assessed on the average: it requires "an average of 40 per annum CPD Hours for the last three years", alongside paid-up subscriptions and no disciplinary case. So a thin year can be carried by a strong one, provided the three-year average holds.

Three categories, three ceilings

Structured units are not fungible. Each category has its own annual maximum:

• Category A — "all courses mounted by ICPAK or by other Professional Accountancy Organizations (PAOs)." Maximum 20 units.
• Category B — courses from "other competent professional regulatory bodies other than PAOs". "Events in category B shall qualify for up to a maximum total of 10 CPD Units in any given calendar year."
• Category C — "Events in this category earn a maximum total of 5 structured units per year".

On the unstructured side there is a further limit: "A single Unstructured CPD activity shall earn not more than 5 CPD units per year."

The arithmetic that catches people

Here is the consequence nobody states plainly. Category A is capped at 20. The structured requirement is 25. So at least 5 structured units must come from Category B or C — from outside ICPAK and outside other professional accountancy organisations entirely.

A member who attends nothing but ICPAK events, however many, reaches 20 structured units and stops. They are five short, and no additional ICPAK attendance will close the gap. The same is true of a member loyal to any single overseas professional body.

This is the inverse of the pattern in most of the region. Elsewhere the home body reserves a minimum for itself — ICAG requires 6 of 35 hours from ICAG-organised events, and MIPA reserves 11 units of 40 for its own or collaborating events. Kenya does the opposite: it caps its own category and effectively forces diversification. We set the regional comparison out in why there is no such thing as African CPD.

What this means for buying training

Three practical points.

First, source structured CPD from at least two category tiers deliberately. A plan built on one provider will come up short by design, not by accident.

Second, check which category a provider actually falls into before buying, because it determines the ceiling. A provider that is a professional accountancy organisation sits in Category A with everything else in that tier, competing for the same 20 units. A regulatory body sits in B. The distinction matters more than the course content when you are near a cap.

Third, for an external commercial provider the realistic ceiling is lower still. Such a provider is unlikely to be a professional accountancy organisation or a professional regulatory body, which points to Category C and its 5-unit annual maximum. That is a real constraint on any market-entry plan in Kenya, and it is set by rule rather than by preference.

Exemption

Members over 60 who are not in practice can apply to ICPAK for exemption from CPD. Note the wording: apply, not qualify automatically.

A date-stamp caution here. The fullest guidance document we could locate on exemptions and the three-year cycle is self-titled "CPD Guidelines 2014". It gives the familiar framing — hours "averaged over a three-year period" and "120 hours in a 3 year rolling cycle" — but it is more than a decade old. ICPAK's current figures above come from its own 2026 member induction material, which we would treat as the better source where the two differ.

Three things we could not verify

We have not been able to establish, from a primary source:

• any formal penalty for shortfall beyond loss of good standing. Good standing has real consequences, but we are not going to describe a sanction we cannot cite.
• a current written CPD policy document. The only full guide we found is the 2014 one above.
• explicit treatment of overseas providers beyond the Category A, B and C structure. The categories imply the answer, but ICPAK does not state it directly, so the Category C inference above is ours rather than theirs.

On that last point, the honest reading is that the category system handles provenance implicitly — what matters is what kind of body ran the event, not where it was. If you need certainty for a specific provider, ask ICPAK which category it falls into before you buy.

A checklist

1. Target 25 structured and 15 unstructured units, and keep the three-year average at 40 or above.
2. Plan for Category A to deliver no more than 20 structured units.
3. Deliberately source at least 5 units from Category B or C.
4. Confirm each provider's category before buying, not after.
5. Remember a single unstructured activity earns no more than 5 units a year.

Full detail on the requirement is in our guide to ICPAK CPD requirements, and the neighbouring Ugandan regime is covered in ICPAU CPD requirements.

This article describes published requirements and is not legal advice. Caps and hour values are revised periodically; verify with ICPAK before relying on this for a compliance declaration.