Philippine CPAs Need 15 CPD Units, Not 120, and That Changes in January 2027

Search for the continuing development requirement for a Philippine CPA and you will find 120 credit units over three years. That figure is in a Professional Regulation Commission matrix, and it is not what is being enforced. The Commission's own frequently asked questions put the requirement for Accountancy at 15 credit units.

And there is a date attached. Professionals who cannot meet even the reduced figure have been allowed to renew their licence on a written undertaking instead. That concession expires on 31 December 2026, with full implementation beginning in January 2027.

The obligation is statutory, and it is not the institute's

This is the structural point that most summaries get wrong. The Philippine Institute of Certified Public Accountants does not impose the requirement. Its own page on CPD reporting and monitoring is an "under construction" placeholder with no requirements on it at all.

PICPA is the Accredited Integrated Professional Organization of CPAs. Under the Continuing Professional Development Act of 2016, its legal role in the system is to supply one member of a council. Section 7 of that Act creates a CPD Council in each regulated profession, and provides that "the first member shall be the president or officer of the AIPO/APO duly authorized by its Board of Govenors/Trustees" — the typo is in the statute as published. That is the whole of PICPA's legal position on continuing development.

The mandate itself is in section 10 of the Act: "The CPD is hereby made as a mandatory requirement in the renewal of the PICs" — the Professional Identification Cards — "of all registered and licensed professionals under the regulation of the PRC." Section 6 gives implementation to the Commission and the professional regulatory boards. The earlier Philippine Accountancy Act of 2004 already required, at section 32, that "all certified public accountants shall abide by the requirements, rules and regulations on continuing professional education", with the Board of Accountancy prescribing them subject to Commission approval.

So the duty runs statute to Commission to Board of Accountancy. The professional body delivers programmes. This is close to the opposite of Malaysia, where the statute is silent and the obligation is a council by-law, and it means a Philippine CPA looking for their rule should be reading Commission resolutions, not institute guidance.

15 units, not 120 — and what each figure is actually for

There are two different numbers serving two different purposes, and conflating them is the single most common error in this area.

For licence renewal. The Commission's matrix of credit units per profession lists Accountancy at 120 units every three years. But under the transition period created by Commission Resolution No. 2019-1146, the operative figure is 15. The Commission's CPD frequently asked questions, in both the 2020 edition and the edition dated 1 February 2024, give Accountancy as 15 credit units in the table for licence renewal, with no age-based or disability-based reduction for the profession. Board of Accountancy Resolution No. 73 of 2019 is the accountancy operational guideline for that period.

Note that 15 is for the compliance period, not per year. Against a three-year cycle, that is an average of five units a year.

For accreditation as a practitioner. Here 120 is real, and this one is in the instruments. Board of Accountancy Resolution No. 27 of 2024, signed on 8 May 2024, states at Rule I section 1 that "the prescribed and earned CPD units to be submitted prior to processing is one hundred twenty (120) CPD units". Its checklists for individual CPAs, firms and partnerships, and individual partners each require "proof of 120 CPD credit units earned showing compliance with the required Competency Area". The Commission's 2026 Citizen's Charter repeats the 120 for CPA accounting teachers, individual CPAs in public accountancy and partners of a CPA partnership, with the first renewal for teachers additionally requiring 12 units of professional education. No CPD requirement appears in the firm or partnership checklist itself.

So a CPA who simply holds a licence is on 15 units for now. A CPA accredited to practise publicly or to teach is on 120. Both figures are correct, for different things, which is exactly why they get mixed up.

The undertaking, and the deadline

The Commission has been rolling forward a concession annually. Where a professional cannot meet the required units, they may renew on an executed undertaking to complete them in the next compliance period. The renewal page sets out the mechanism and also the requirement to "present your CPD Certificates indicating CPD credit units earned upon claiming your PIC".

The extensions run: Resolution No. 1773 of 2024 to 31 December 2024, Resolution No. 1908 of 2024 to 31 December 2025, Resolution No. 2136(A) of 2025 to 30 June 2026, and Resolution No. 2200 of 2026, approved on 22 June 2026, which extends acceptance of the undertaking "until 31 December 2026".

That resolution also states why: to give the Commission and professionals time to prepare for full CPD implementation, which begins in January 2027, through orientations, a revised Citizen's Charter and an enhanced accreditation system.

What the requirement becomes in January 2027 is not stated. The 120-unit matrix is undated and was the pre-transition figure. We are not going to assert that it returns, because no resolution we could read says so. What is certain is that the undertaking route closes on 31 December 2026.

Self-directed learning is capped at 30 per cent

The Commission's vocabulary is its own and should not be translated. It counts credit units, organised by Competence Areas, and distinguishes formal from non-formal activity, with Self-Directed Learning as a named category.

The cap is firm: "Only 30% of the required CPD credit units per compliance period can be earned under SDL activities", and excess units are not carried over. Against 15 units, that is five.

The ethics allocation cannot be stated, and is currently switched off anyway

There are three competence areas, renamed from "thematic areas" by Board Resolution No. 358 of 2016: Technical Competence; Professional Skills; and Professional Values, Ethics and Attitudes. The same resolution raised the requirement from 60 to 120 units and phased it 60, 80, 100, 120 across 2016 to 2019.

But no document we could read assigns units to those areas. The Commission's announcement gives none. The matrix gives none. Resolution 53 of 2022 gives none. Resolution 27 of 2024 refers only to "the required Competency Area" without numbers. The document that would state them — Board of Accountancy Resolution No. 2017-254, the operational guidelines for accountancy — is published as an image scan with no extractable text, and we do not work around that. So we are publishing no ethics unit figure for the Philippines.

In any event, area-level compliance is currently suspended. The Commission's frequently asked questions state: "Compliance with the required CPD credit units per Major Area of CPD Activities is hereby suspended", and professionals may earn units from any major area. Like the two parallel regimes in Singapore, the structure on paper and the structure in force are not the same thing.

No exemptions, and no annual declaration

The Commission is blunt about exemptions: "The Law does not provide any exemption from CPD compliance for the renewal of Professional Identification card." The reduced-unit table that gives some professions relief by age bracket gives Accountancy none. The Act itself contains no exemption provision.

Two transition-period reliefs do exist. Professionals working overseas must provide a valid certificate of employment or an overseas employment certificate approved by the relevant authority. Newly licensed professionals are relieved for their first renewal after licensure. Neither relief covers professionals intending to practise in countries under arrangements that recognise CPD as an eligibility requirement, such as the ASEAN Mutual Recognition Arrangements.

There is no annual declaration at all. Compliance is proved at the point of licence renewal, which runs on the professional's birth month on a three-year cycle. We could not retrieve an express statement of the compliance period's start and end dates, so we are not giving one. We also found no record retention period in the Act, the earlier Act, the frequently asked questions or either accreditation resolution.

What non-compliance costs

Short of the units, a professional renews on the undertaking — until 31 December 2026. Beyond that, the licence is not renewed, because the Act makes CPD a mandatory requirement of renewal. Practising or teaching without accreditation, or on expired accreditation, is dealt with under the Accountancy Act's own penalty provisions. And fraudulent acts in CPD implementation attract, under section 16 of the Act, penalties under the Revised Penal Code together with "suspension or revocation" of the Certificate of Registration.

No sample rate and no compliance statistics are published. Accreditation validity is tied to the applicant's birth month and capped at three years, with renewal required at least three months before expiry of both the accreditation and the licence.

The renewal mechanism, including the undertaking, is set out on the Commission's licence renewal page.