PSRA CPD for Property Services Licensees: Five Hours, and the Only Irish Regime That Prescribes the Content

Every Irish CPD regime covered so far sets a number of hours and leaves the content to the practitioner. The Property Services Regulatory Authority does something no other Irish regulator in this set does: it tells licensees what the hours must be about, down to the half hour.

Five verifiable hours of formal CPD a year is a modest requirement by professional standards. The prescription inside those five hours is what makes the regime unusual, and it is also what makes it easy to fail while technically having done the training.

The requirement, and who carries it

Licensees must complete at least five verifiable hours of formal CPD each year. The scheme counts hours rather than points, and the Authority reserves the right to change the number at any time.

It applies to licensees holding categories A, B, C or D, or any combination of them, and to partners in a partnership individually. Where the licensee is a body corporate, the obligation takes a different shape: the company must ensure that its principal officers maintain their professional competence.

The CPD year ends on 31 December. Surplus hours cannot be carried forward into the next year, and a licensee first licensed part-way through the year has a pro rata requirement rather than the full five hours.

The prescribed content, which is the real obligation

This is the part that distinguishes the scheme. The five hours are not free-form:

• at least 2 hours in General and Management;
• at least 2 hours in Legislation and Regulation;
• the final hour from either category.

And within the Legislation and Regulation allocation, two specific topics are mandated: one hour must cover the Property Services (Regulation) Act 2011, and half an hour must cover anti-money laundering.

Two further mechanical rules shape how the hours can be assembled. Each course must run for at least 30 minutes to count at all, and a single sub-category can contribute no more than one hour. So a licensee cannot satisfy the requirement by doing five hours on whichever single topic happens to interest them, and cannot pad it with a series of ten-minute modules.

The mandated AML half hour is worth pausing on, because it means property services is one of the few sectors where anti-money laundering training is not merely expected under the AML legislation but written into the CPD scheme as a minimum. It sits alongside the substantive obligations we set out in our guide to AML obligations for estate agents and auctioneers under the PSRA, and the half hour is a floor for the CPD scheme rather than a measure of what the AML regime itself requires.

Accredited providers, and why that matters

The Authority's accreditation function sits under section 79(2)(b) of the Property Services (Regulation) Act 2011, and the scheme runs through accredited providers rather than leaving relevance to the licensee's judgement.

Licensees sign in and out at CPD events. Accredited providers issue certificates showing the licensee's name, licence number, category, sub-category, delivery method and hours, and the licensee must keep those certificates. The Authority audits licensees regularly and can require providers to supply attendance information directly.

That last power is the one that changes the risk calculation. In regimes where evidence comes only from the practitioner, a weak record is a documentation problem. Here the regulator can go to the provider, which means the attendance record exists independently of whatever the licensee has kept.

This provider-accredited model is closer to the veterinary approach, where activities must be accredited by the Veterinary Council, than to the CORU model, where there is no approved provider list and the registrant carries the burden of justifying relevance.

What non-compliance actually triggers

Failure to meet the CPD requirements can amount to improper conduct, which is a defined term in section 2 of the Act, with the relevant non-compliance provisions at sections 81(1) and 81(2).

The route from there is a complaint under Part 7 of the Act, which can lead to an investigation and a sanction. That is a materially different mechanism from the two extremes elsewhere in Irish professional regulation: it is neither the automatic statutory removal that section 17A imposes on the RIAI for registered architects, nor the unpublished internal consequence of a membership-based scheme such as Engineers Ireland's. It is a conduct process, with the findings and sanctions that implies.

Reductions are available and have to be asked for. Pro rata reductions may be granted for statutory maternity, adoption, parental or carer's leave, and for illness or other circumstances lasting two months or more, as the Authority deems appropriate. Requests must be made in writing — the reduction is not automatic on the facts.

The contrast next door: security licensing with no CPD at all

Ireland licenses the private security industry through a separate regulator, and that regime is built on the opposite principle. It gates entry on a named qualification and requires nothing thereafter.

Under the Private Security (Licensing and Qualifications) Regulations 2022, S.I. No. 574 of 2022, which came into operation on 1 November 2022 and revoked the 2006 Regulations, Regulation 6 sets the qualification for each licensable sector:

• Door supervisor — QQI Level 4 Minor award 4N20611, Door Security Skills, or equivalent;
• Security guard — QQI Level 4 Minor award 4N20604, Security Guarding Skills, or equivalent;
• Private investigator — the PSA's own training requirements document, PSA 83:2021, rather than a named QQI award.

"Equivalent" means whatever the Private Security Authority considers equivalent to the named award. The Regulations were subsequently amended by S.I. No. 204 of 2024.

The Regulations impose no recurring CPD cycle, but they are not silent on retraining, and the 2024 amendment changed the position materially. S.I. No. 204 of 2024, in force from 8 May 2024, created a new enforcement guard licence with its own qualification — QQI Level 4 Minor award 4N22384, Enforcement Guard Skills — and replaced the transitional provision. Existing door supervisor and security guarding licence holders may continue working until their scheduled renewal date, and at renewal they must complete the prescribed training course and apply for an enforcement guard licence. There is therefore a mandatory retraining event, triggered by each licence holder's own renewal anniversary rather than by a common deadline. We set out the detail in our guide to PSA licence qualifications and the enforcement guard licence. Operators running public-facing venues should note that obligations such as Martyn's Law public protection procedures and general workplace compliance training duties run independently and will not be satisfied by a licence qualification held years earlier.

What the comparison shows

Put the two Irish regimes side by side and the design choice is stark. Property services: low hours, prescribed content, accredited providers, regulator can audit the provider, non-compliance is conduct. Private security: a one-time named qualification, no hours, no content prescription, nothing ongoing.

Neither is obviously the stronger model. Five prescribed hours a year will keep a property services licensee current on the 2011 Act and on AML whether they want to be or not. A security qualification from four years ago will not keep anyone current on anything. But the property services licensee can also discharge the whole obligation in a single afternoon, which is not a serious continuing education programme by the standards of framework-based approaches such as the Teaching Council's Cosán.

Our suggestions

For property services licensees, build the year from the mandated items backwards: the hour on the 2011 Act and the half hour on AML are fixed, so plan those first and fill the General and Management allocation around them. Keep every certificate, because the Authority audits regularly and the certificate is what carries your licence number against the hours.

Watch the 31 December line and the no-carry-forward rule together. An ambitious year does not bank anything for a difficult one, which makes a late-year shortfall genuinely unrecoverable.

If you are a body corporate, read the obligation as it is written — it bites on the professional competence of your principal officers, not on a company-level training statistic.

And if you hold a security licence, do not read the absence of a refresher requirement as an absence of risk. The regulations are silent on currency; your customers, insurers and the separate statutory duties attaching to your premises are not. Firms with AML exposure should also keep the AMLA regulation and the obligated-entity perimeter in view, along with the UK guidance for estate agents where there is cross-border activity.