The Dutch Accountancy Regulator Sets No CPD Hours At All

Every body we have documented so far answers the question "how much continuing development must I do?" with a number. The Netherlands does not answer it at all, because there is no number to give.

The Nadere voorschriften permanente educatie 2026, in force since 1 January 2026, contains no hours, no units, no credits, no annual figure and no multi-year total. What it requires instead is a portfolio.

The instrument, and where its authority comes from

The governing text is the Nadere voorschriften permanente educatie 2026 — further rules of 4 November 2025 on the continuing education of accountants — published in the Dutch government gazette on 18 November 2025 and in force from 1 January 2026. One article, on sustainability assurance, commences later with the implementing legislation for the sustainability reporting directive.

It is a professional body regulation rather than a statute, and the chain runs through three levels. The Act on the Accountancy Profession empowers the members' meeting to make regulations. Under that power the professional conduct regulation imposes, at article 12, the substantive duty: the accountant "maintains his professional competence at the level required to provide a professional service adequately" — our translation. Article 24 of the same regulation then lets the board lay down further rules, and the 2026 rules are made under it.

So the Dutch duty is a competence duty first and a documentation duty second. The hours question never enters.

What is actually required: a portfolio with eight elements

Article 4 requires every accountant to keep a continuing education portfolio, and specifies its contents. In our translation, those are: the accountant's name; the role the accountant performs; the current or future work that gives rise to a learning objective; the learning objectives for each piece of work; a consideration of the development themes the board has set; the activities performed during the calendar year; documents making it plausible that those activities were performed; and the learning outcomes achieved.

Read that list carefully, because the logic runs in the opposite direction from an hours regime. It starts with the work the accountant does, derives learning objectives from it, and ends with outcomes. Activity sits in the middle as a means rather than as the thing being measured. An accountant who attended fifty hours of courses with no stated objective and no recorded outcome has not complied; an accountant who attended rather less, against clear objectives, with outcomes recorded, has.

The regulation also uses none of the vocabulary the rest of the world uses. There is no structured and unstructured, no verifiable and non-verifiable. The nearest thing is the evidence requirement in article 4(2)(g), which asks for documents making it plausible that an activity happened — a test of whether it occurred, not a classification of what kind of learning it was.

One word of caution if you write about this. The Dutch model is often described as a "lerend vermogen" or learning-capacity model, and that phrase does not appear in the regulation, in its explanatory notes, or on the regulator's current policy page. The notes speak of "the focus on development and the capacity for it" and call accountancy "a learning profession". The label is a description of the model, not a quotation from it.

Development themes are mandatory to consider, not mandatory to do

This is the subtlest part of the design. Article 5(1) lets the board set development themes per field of work for a three-year period. Article 5(2) then provides that the accountant decides each year whether to adopt a theme as a learning objective — and must explain the choice where a theme is left out.

So even a theme the board has set is not a required subject. It is a required consideration, with a reasoned explanation owed if it is declined. That is a genuinely different instrument from a mandated subject, and it is why the Netherlands appears nowhere in the comparison of mandatory ethics hours across bodies: there is no ethics figure, because ethics is not a named mandatory subject in the regulation at all.

A second power, in article 9(1), lets the board set a knowledge area or topic for a defined group of accountants, to be undertaken "to an extent to be further determined" — the only quantity-like phrase in the whole instrument, and it fixes nothing.

Six years of retention, with the reasoning published

Article 6(1) requires the portfolio to be kept for at least six years. The explanatory notes give the reasoning, which is unusually transparent: six years matches the normal firm quality-review cycle and sits inside the ten-year limitation period for disciplinary proceedings.

Six years is longer than almost anything else in this field — longer than the five years most Canadian regulators and US state boards use, and far longer than Pakistan's one year after the cycle closes. It follows from the design. If compliance is judged on the quality of a portfolio rather than the count of hours, the portfolio has to survive long enough to be judged.

The annual compliance declaration is due by 31 January, confirming whether the obligations have been met, submitted through the regulator's member portal.

A sampling design that is actually published

Most bodies say they audit a sample and publish no rate. The Dutch regulator publishes the design.

Its supervision framework describes a stratified random sample of the whole membership, calibrated so that each accountant is assessed on average once every six years. Accountants are placed in one of three probability classes based on working environment and prior assessment result, with a previous satisfactory result putting the accountant in the lowest class. Members selected are notified in February and must produce the portfolio within ten working days of a request, with requests spread across the year. Two assessors review each portfolio, and where they diverge by more than fifteen percentage points, or split on the outcome, a third assessor decides.

Article 8 keeps the outcome binary: the portfolio either satisfies or does not satisfy. Worth noting that the published supervision framework still refers to the superseded 2019 rules and their older grading language, so the framework and the current regulation are not yet aligned on vocabulary.

The regulation deliberately imposes no sanction

This is the most interesting legal point in the whole instrument, and the explanatory notes state it openly: the power of an administrative body to impose a sanction must be laid down in an act in the formal sense. The board cannot create sanctions in its own further rules, so it has not tried.

What it can do is complain. The notes say the regulator may bring a complaint about non-compliance before the disciplinary court, and set out a graduated approach: a portfolio that does not satisfy — where none was submitted, essential parts are missing, or the elements lack internal consistency — does not lead immediately to a complaint. The accountant gets a chance to submit a compliant portfolio, together with an offer of a support conversation with an educational adviser. Only if that chance is not used does the file go to the disciplinary court. Failing to submit the compliance declaration at all, or submitting it and then being unable to produce a portfolio, can likewise lead to a disciplinary complaint.

So the Dutch enforcement route is professional discipline rather than administrative suspension — closer to the Quebec model's endpoint than to the suspension-and-cancellation ladders used across the rest of Canada and in Asia.

Exemptions, and who is outside the rules entirely

Article 10 gives the board two tools: it may grant exemption from the portfolio, themes, declaration and topic provisions, and it may grant relief where the accountant demonstrates that compliance cannot reasonably be met.

Separately, article 2 excludes non-active members from the regulation altogether — they are outside its scope rather than exempted within it.

Transitionally, article 11 keeps the 2019 rules in force for assessing the 2025 obligations, so an accountant being reviewed for 2025 is judged against the old instrument.

Why this matters beyond the Netherlands

The international standard that most bodies cite as the source of the 120-hours-over-three-years figure does not require hours. Its own illustration of an input-based approach is just that — an illustration — and it explicitly contemplates output-based measurement instead. The Netherlands is the clearest demonstration available that a body can comply with the standard while setting no hours figure at all, and it is worth holding up against the fourteen bodies in this programme that landed on some variant of 120 and 20.

It also means that a Dutch accountant with dual membership elsewhere has an asymmetric problem. Their Dutch obligation cannot be discharged by counting hours, and their foreign obligation cannot be discharged by a portfolio. The two tests do not convert into one another in either direction.

The regulator's current policy position is set out on its continuing education policy page.