Quebec CPAs Need 25 CPD Hours a Year, Not 20, and No Verifiable Hours at All

Almost everything written about Canadian CPA continuing professional development says 120 hours over three years, 20 hours a year, 60 of them verifiable, on a rolling cycle. In Quebec, one of those four statements is true.

The 120 holds. The annual minimum is 25, not 20. There is no verifiable-hours requirement at all. And the cycle is fixed rather than rolling, running on a September-to-August year. A Quebec CPA working from the standard Canadian summary is managing to the wrong number on three dimensions out of four.

The legal architecture, which has to be stated correctly

Quebec is not a jurisdiction where the regulator writes its own by-laws and that is the end of it. The Ordre des comptables professionnels agréés du Québec is a professional order under Quebec's Code des professions, and its continuing education obligation sits in a government-approved regulation published in the Compilation of Québec Laws and Regulations: C-48.1, r. 17, made under section 2 of the Chartered Professional Accountants Act and paragraph (o) of section 94 of the Professional Code.

That is a different order of instrument from Ontario's Regulation 7-2, which CPA Ontario's own Council adopts, or British Columbia's bylaw regulations, which its board makes. Quebec's regulation passes through the Professional Code's regulation-making process and is published in the Gazette officielle du Québec. Calling it "Quebec's by-law" is a category error, and any Quebec reader will notice.

There are also two regulations, not one. Every Quebec CPA is subject to r. 17. Holders of a public accountancy permit are additionally subject to C-48.1, r. 18, which has its own hours figure. And a third tier sits underneath both: the Ordre's board-adopted Programme de formation continue et modalités d'application, approved 6 June 2025 and in force 1 September 2025. As we will see, several of the obligations people attribute to the regulation actually live in that programme.

25 hours a year, and what that does over a cycle

Article 2 of r. 17 requires at least 120 hours of continuing education directly related to the member's fields of activity, per three-year reference period, with "un minimum de 25 heures par année de référence".

Twenty-five rather than twenty sounds like a minor difference. Over a full cycle it is not. Three years at 25 locks in 75 of the 120 hours through the annual floor, against 60 everywhere else. That leaves a Quebec CPA 45 hours of discretion across the period where a CPA elsewhere has 60. For anyone who front-loads or back-loads learning around a busy season, Quebec's floor is materially more constraining, and it is the figure that binds in practice.

There is no verifiable-hours requirement in Quebec

This is the correction most likely to mislead someone. Every common-law Canadian jurisdiction we examined uses a verifiable and unverifiable split, whether drafted as 60 of 120 and 10 of 20 or, as in Ontario, as a flat 50 per cent rule applied to both figures. Quebec uses none of it. The words do not appear in the requirement.

What Quebec does instead is the inverse. Article 2 caps self-study at a "maximum de 15 heures par année de référence". Rather than setting a floor on externally evidenced learning, it sets a ceiling on learning you do alone. The quality concept Quebec uses is "structured", not "verifiable".

These are not the same test and a course can satisfy one without satisfying the other. Any summary that says Quebec requires 60 verifiable hours is simply wrong, and a dual registrant cannot assume that mapping hours to one test maps them to the other.

A fixed cycle, with a hard cliff — but the dates are not in the regulation

The widely repeated claim that Quebec runs a different cycle is correct. The current reference period runs from 1 September 2025 to 31 August 2028, on a reference year of 1 September to 31 August. Everywhere else we examined runs a rolling three-year period on the calendar year.

The practical difference is large. Elsewhere the window moves continuously and the oldest year drops off each 31 December, so a shortfall can be made up in the following year without the cycle ever closing. In Quebec there is a hard cliff on 31 August 2028. These are different compliance problems and they cannot be managed with one plan.

But note where the dates come from. Article 6 of r. 17 delegates them: the Order fixes the date on which the reference period begins and ends. The 2025 to 2028 window is the Ordre's published period, not a figure in the regulation. The same is true of r. 18, whose section 4(1) likewise requires the Order to fix the start and end dates.

The ethics hours are not in the regulation either

Quebec is usually described as requiring four hours of professional ethics training, and in substance that is true. The attribution is wrong.

C-48.1, r. 17, as consolidated to 1 July 2026, contains no ethics hours requirement. Article 5 lists admissible subject areas, among which professionalism and ethical behaviour appear as one eligible topic, with no minimum attached to it anywhere in the instrument.

The four hours come from the Ordre's programme: a minimum of four hours of structured training in fields related to professional ethics, per three-year reference period. The programme is a board-adopted instrument made under the regulation, and that distinction has teeth — an obligation in a board-adopted programme can be changed faster, and by a different process, than one in a government-approved regulation.

Two further Quebec obligations have no counterpart anywhere else in Canada. Members must take, once, a mandatory three-hour training course on the CPA Code of ethics. Members who provide services to third parties must take a further complementary hour, which also counts as ethics. And a course on the CPA Code of ethics must be pre-approved by the Order, except for the independence rule. Quebec is the only jurisdiction we examined that pre-approves ethics course content rather than publishing criteria and leaving members to self-assess. An ethics course accepted in Ontario or British Columbia will not automatically satisfy Quebec.

Self-study hours count toward neither the ethics requirement nor the public accountancy requirements.

Twelve months of record retention, against five years everywhere else

Article 11 of r. 17 requires documents supporting declared hours to be kept until twelve months after the end of the reference period. Section 9 of r. 18 says the same for permit holders.

Ontario, British Columbia, Alberta, New Brunswick, Nova Scotia and Newfoundland and Labrador all use five years. Depending where in the cycle an activity falls, a Quebec CPA's retention duty can expire years before an Ontario CPA's for the identical course. It is the sharpest proportionate divergence on any administrative dimension in the country, and it runs in the opposite direction to the long retention periods US state boards tend to impose. A dual registrant should keep to the five-year rule regardless and should not assume Quebec's shorter period offers any protection for the other province.

The deadline is 30 September, and the endpoint is harsher than elsewhere

Article 7 of r. 17 requires the report to be sent no later than thirty days after the end of each reference year. The reference year ends 31 August, so hours must be complete by 31 August and declared by 30 September. That is the latest continuing education declaration deadline in Canada, eight months after British Columbia's 31 January.

The default process runs on a published timetable. A notice of default and an invoice for $175 issue in October, with thirty days to regularise and pay. A final notice follows in November if the matter is unresolved, carrying a further fifteen days. Then the executive committee decides, and article 19 of r. 17 sets out what it can do: suspend or limit the member's right to practise professional activities, or strike the member off the roll of the Order. Articles 17 and 18 fix the intervening periods — the remedy period may be neither less than thirty days nor more than sixty, and the final notice grants an additional fifteen days from receipt.

Striking off is a materially harsher published endpoint than the suspension-then-cancellation sequence used elsewhere in Canada, and it is framed in the language of the Professional Code's disciplinary architecture rather than of administrative membership status.

The public accountancy add-on specifies 60 of the 120 rather than adding to them

Section 1 of r. 18 requires permit holders to complete, in every three-year reference period, at least 60 hours of continuing education activities including a minimum of 15 hours per reference year. Read alone that looks like an extra 60 hours on top of the 120. It is not.

Per the Ordre's programme, auditors need the same 120 hours with 25 a year, and within that a minimum of 15 hours a year in fields related to audit engagements and a minimum of 56 structured hours in those fields across the period. The 56 audit hours plus the four ethics hours are what make up the 60 that r. 18 requires. It is a specification of part of the 120, not an addition to it — and it is the only public accountancy overlay in Canada contained in a separate binding regulation with its own hours figure.

Section 16 of r. 18 provides that where a failure is not corrected, the Order shall suspend or revoke the member's public accountancy permit, and section 17 that the permit remains suspended until the member provides proof the requirements have been met. Like r. 17, r. 18 contains no ethics-specific requirement of its own.

Exemptions, which are narrower than the usual list

Article 14 of r. 17 exempts a member who demonstrates that it is impossible to complete the training, for a period that may not exceed twelve months and may be renewed. The exemption cannot arise from a striking-off, suspension or limitation imposed by the disciplinary council, the Professions Tribunal or the board. Article 16 exempts a retired member on the roll who does not practise the profession throughout the period.

The Ordre's published grounds are illness, with up to three months counted where a phased return follows; parental leave; acting as a natural caregiver; and establishment in a remote region where online training is not possible. That last ground is unique in Canada among the instruments we examined. Requests must be filed by 31 August of the reference year, may be granted for a maximum of twelve months at a time, and are renewable except for parental leave in respect of the same child. Heavy workload, a sabbatical and job-seeking are expressly not grounds.

New members are prorated by the remaining months under article 3, and training taken before the permit issue date cannot be declared — the opposite of Newfoundland and Labrador, where learning completed in the admission year, including professional education program modules, may be counted.

One thing we could not resolve, and you should know about it

The LégisQuébec table-of-contents page for C-48.1, r. 17 displays "Remplacé le 2 novembre 2026" — replaced on 2 November 2026. The consolidated document page for the same regulation, which carries the notice that it has official value, shows "À jour au 1er juillet 2026", carries no replacement marker, and its historical note contains no 2026 entry. No successor regulation is identifiable, no Gazette officielle notice could be found, the Ordre's own French pages say nothing and still cite the regulation by its existing title, and r. 18 carries no equivalent marker.

So two official pages for the same instrument disagree, and we could not establish which is right. Either a replacement came into force on 2 November 2026 and the consolidation and index had not caught up, or the marker records a republication event rather than a substantive change. We are not going to characterise it without a Gazette citation or a statement from the Ordre.

Everything above is sourced to the 1 July 2026 consolidation of r. 17 and the programme in force from 1 September 2025. If a new regulation did take effect on 2 November 2026, these figures may be superseded — and that would itself be significant news for Quebec CPAs, which is precisely why we are flagging it rather than quietly presenting the figures as settled. The same caution applies to every other Canadian jurisdiction's instrument, because the rules are provincial and change on provincial timetables.

Primary source: C-48.1, r. 17, consolidated to 1 July 2026, on LégisQuébec. The Ordre publishes no English version of its own continuing education requirements, so the French text is the only authority — which for Quebec legislation it is in any event.