Japan Is the Rare Place Where a CPA’s CPD Hours Are Fixed by Government

Across the bodies we have documented so far, the hours figure almost never lives in legislation. Malaysia's Accountants Act is silent on it. Nigeria's ICAN Act has no continuing development provision at all. Canada's ten provincial regulators mostly put it in their own by-laws, directives or board policies. Japan is the exception: the number of credits a Japanese CPA must complete each year is fixed by a Cabinet Office Ordinance, and the regulator's compliance reporting goes to the Financial Services Agency every six months.

That changes the character of the obligation, and it shows in the enforcement.

Three layers, and the number is in the middle one

The statutory hook is article 28 of the Certified Public Accountants Act. JICPA's own Japanese page puts the date on it: 2004年4月からは公認会計士法第28条において法定義務化されております — from April 2004 it was made a statutory obligation under article 28 of the Certified Public Accountants Act. We should say plainly that we did not read article 28 itself; the official translation page for the Act was not retrievable, so the statutory hook is established from JICPA's own description of it in two languages rather than from the text.

The figure itself is one layer down, in a government instrument we did read: the Cabinet Office Ordinance on Continuing Professional Education Prescribed in Article 28 of Certified Public Accountants Act, Cabinet Office Ordinance No. 17 of 2004, enacted 25 March 2004. Its article 1(1) requires a certified public accountant, per business year, to participate in continuing professional education offered by JICPA "to acquire 40 credits or more". Article 1(2) defines the unit: "one hour of continuing professional education conducted by way of lecture shall constitute one credit", with the Institute setting the conversion for other formats.

So the statutory annual figure is 40 credits, on a business year running 1 April to 31 March. Not 120 over three years.

The 120 comes from the third layer, JICPA's own Articles of Association, last amended 23 July 2025. Article 122(4) requires members to satisfy three things at once: the total required credits for the three business years up to and including the current one, less what was completed in the two preceding years — which with the Ordinance's 40 produces 120; a floor of 20 credits; and the mandatory subject counts prescribed by JICPA's training bylaws. JICPA's English page states the result plainly as 120 credits over three years with a minimum of 20 credits annually.

Since financial year 2023 the smallest declarable unit has been half a credit.

There is no verifiable or structured split in Japan at all

This is worth stating clearly because almost every other body in the world has one. Japan does not. Neither the Ordinance, nor the Articles of Association, nor JICPA's current pages draw a distinction between verifiable and unverifiable, or structured and unstructured learning. The vocabulary is 研修科目, subject, and 単位, credit, with a format-based conversion rule the Institute sets.

That makes Japan structurally closer to Quebec, which also operates no verifiable split and uses a different quality concept entirely, than to the Anglophone bodies. Do not map one body's vocabulary onto another's; the tests are not interchangeable and a course that satisfies one may not satisfy the other.

The mandatory subjects, which are more prescriptive than most

Three mandatory subject requirements run alongside the totals, and all three sit in JICPA's own training bylaws rather than in the statute or the Ordinance.

Professional ethics, 職業倫理, is two credits a year for all members, mandatory since financial year 2006. Tax, 税務, is two credits a year for all members, mandatory since financial year 2014 — a mandated subject that is not ethics, which is unusual. And audit quality and fraud risk response, 監査の品質及び不正リスク対応, is six credits a year for members engaged in statutory audit, of which at least two must be fraud case study, 不正事例研究, a sub-requirement added in financial year 2016.

That is a member in statutory audit practice carrying ten prescribed credits a year out of a 20-credit annual floor, with only half the floor left to their own judgement. By comparison, ICAEW mandates a single hour of ethics and nothing else, and ACCA mandates no subject at all.

A warning for anyone researching Japan in English

JICPA's legacy English pages are still live, still indexed, and wrong. They state four credits of professional ethics, four credits of audit quality control, and a flat requirement of at least 40 credits annually with no three-year rule. That page is dated to April 2006 and reflects the system as it then stood.

The current figures are two, two and six, with the 120-over-three-years and 20-annual structure on top. IFAC's own member page for JICPA matches the current Articles of Association, which confirms the legacy page is the outlier rather than the other way round. If you find a source citing four ethics credits for a Japanese CPA, it is reading the stale page.

Enforcement: public disclosure, and the longest published ladder we have found

Japan does not sample. It runs a census of declared credits, tallied centrally, and then publishes the result member by member.

JICPA announced on 24 August 2018 that it would disclose members' training completion results — 会員の研修履修結果を開示することといたしました — viewable for each individual member through the CPA search system, 公認会計士等検索システム. Anyone can look up a named Japanese CPA and see whether they met their requirement. No other body we have examined does this.

Behind that sit two further mechanisms. Audit firms must supervise their member partners and staff for compliance under article 122(5). And article 4 of the Ordinance requires the FSA Commissioner to call for JICPA's training plan and implementation status every six months, which makes the Institute's administration of the programme itself a matter of government oversight rather than self-regulation alone.

The escalation, drawn from the Articles of Association and JICPA's Japanese page, runs year on year. First a 履修指示, a directive to complete training, issued by the Chairman under article 128(1). Then 氏名等の公示, public notice of the directive, after board approval. Then, where a member ignores the directive and falls short again the following year, 公表, public disclosure. Then a recommendation to withdraw from audit engagements, 監査業務の辞退勧告. Then discipline: the CPD Council prepares a proposal and the Chairman refers it to the Disciplinary Review Board, with reprimand or suspension of membership rights available. JICPA may additionally request the FSA Commissioner to impose an administrative disposition.

And at the end, deregistration. Members recording zero credits for three or more consecutive years are liable to 登録抹消, removal from the register, measured from financial year 2023 results under the amended Act effective 1 April 2023. That is the loss of the qualification itself, not merely of membership standing.

The only compliance statistic JICPA has published is from 2018 and relates to financial year 2017: an obligation-achievement rate of 98.8 per cent. We found nothing more recent, and its financial year 2023 business report carries no completion rate, no count of directives issued and no count of deregistrations.

Exemptions are a government decision, not the Institute's

This is the sharpest consequence of the statutory architecture. Japan's exemptions are in the Cabinet Office Ordinance, and they require the approval of the FSA Commissioner.

Article 2 grants full exemption where, throughout a business year, the person does not and is not expected to perform services as a certified public accountant by reason of illness, holding public office, full-time government service, or certain non-resident status. The application goes to the JICPA Chairman and is approved by the Commissioner.

Article 3 grants a reduction on the same grounds where they cover a substantial part of a business year, on a sliding scale set out in an appended table: five credits off where the person did not practise for between one-eighth and under one-quarter of the year, rising to 35 credits off at seven-eighths or more.

Compare that with almost anywhere else, where the regulator's own registrar or membership committee decides. In Japan a government official signs off an individual accountant's reduced training requirement. That is the clearest illustration available of why the instrument a requirement sits in matters as much as the number in it, and it is the opposite end of the spectrum from a jurisdiction whose statute is silent and whose obligation rests on a council by-law.

What we could not establish

Three things, and we are not going to fill them in. JICPA's training bylaws, the 研修細則, were not retrievable at any URL, so the two, two and six figures rest on three separate JICPA descriptions rather than on the rule text. No declaration deadline is stated on any current JICPA page or in the Articles of Association — the 30 April date that circulates comes from the stale English page, which is demonstrably wrong on other figures. And no record retention period appears anywhere in the Ordinance, the Articles of Association or any current page; we think it is genuinely absent from the system rather than merely unfound, but we have not verified that.

Primary source for the 40-credit figure: Cabinet Office Ordinance No. 17 of 2004, bilingual official translation.