SOCPA Asks for 65 CPE Points a Year and Publishes a Repealed Law as Its Basis

SOCPA requires its licensed full members to complete 65 continuing professional education points a year. We can tell you that figure with reasonable confidence. What we cannot tell you — and what nobody writing about Saudi accountancy appears to have noticed — is which instrument imposes it, because the statute SOCPA's own English website publishes as the governing law was repealed in 2021, and the current law contains no continuing education obligation at all.

The repealed law still on the regulator's site

SOCPA's English "Accountant's Regulations" page sets out the Certified Public Accountants' Regulations approved by Royal Decree M/12 of 13/5/1412H. Article 11 of those regulations provides that a certified public accountant "shall undertake to attend a given number of seminanrs as may be specified and held by SOCPA" — the misspelling is in SOCPA's own published text. Article 19 tasks SOCPA with organising courses of continuous education, and article 25 empowers the board to organise programmes and courses of continuous education.

That is the document most sources rely on. It is no longer the law.

The current statute is the Accounting and Auditing Profession Law of 1442H, corresponding to 2021, cited in its own executive regulation as Royal Decree م/59 of 27/07/1442H. We read it. Its article 21 states: يحل النظام محل نظام المحاسبين القانونيين الصادر بالمرسوم الملكي رقم (م/12) وتاريخ 1412/5/13هـ — our translation: "This Law replaces the Accountants Law issued by Royal Decree No. (M/12) dated 13/5/1412H", and it repeals any conflicting provisions of that earlier law. Article 22 provides for the Minister of Commerce to issue executive regulations within ninety days, with the Law taking effect ninety days after publication in the Official Gazette.

So the instrument whose article 11 is universally cited as the basis of Saudi continuing education has been expressly displaced, and SOCPA continues to publish it in English as the regulations governing accountants.

The 2021 law imposes no continuing education duty

We looked for a successor provision in the new Law and there is none. Its only reference to training is article 16(1), which appears among the corrective measures available against a practitioner who has violated the Law: إلزامه بحضور دورات تدريبية محددة — our translation: "obliging him to attend specified training courses".

That is a sanction, not an obligation. It applies to someone who has already breached the Law. It is not a standing continuing education requirement on the profession.

We also read the executive regulation of the 2021 Law. It contains no continuing professional education article either. One caveat we will not paper over: in extraction, articles 3, 10 and 13 came through as headings only, so a provision could be sitting inside one of them that we did not see.

Where the obligation now rests, and why we cannot cite it

On SOCPA's own account, the duty is a condition of membership rather than of law. Its professional membership and full member pages list among members' obligations "completing all of the Continuous Professional Education Program (CPE) requirements", and point to two documents: "Section (2) of the membership regulations" and, for suspension, "Internal Regulations, Article XIII, paragraph 13/5".

Neither document was retrievable. We therefore cannot give the instrument a name, a number or an edition date, and we cannot quote a continuing education clause from it. We do not know whether it is a by-law, a general assembly regulation or a board resolution.

Four SOCPA documents that would most likely have resolved it, including both of its continuing professional education programme files and its 2021 organisational statute, are disallowed to automated retrieval on both of SOCPA's hosts, and the official Bureau of Experts text of the Law is likewise disallowed. We do not work around that kind of restriction, so these are recorded as unread rather than as absent.

This puts Saudi Arabia in the same structural position as Nigeria, where the statute has no continuing development provision and the obligation is council policy enforced through licence conditions — except that ICAN at least publishes a page setting out its figures under its own name, while SOCPA's figures appear on a membership page and its governing rules do not appear at all.

The points, and the two lines we are not going to interpret

From SOCPA's membership page, which is a web page last updated in July 2021 rather than an instrument: licensed full members require 65 points annually. Non-licensed full members, those who have passed SOCPA's fellowship exam without holding membership, and technical employees at accounting firms require 50 points annually.

Those two figures are independently stated on IFAC's member page for SOCPA, with the same four categories. That is corroboration, not a second primary source — IFAC's profile is compiled from the body's own submissions.

The same SOCPA page also carries two further lines: "Practitioner Full Members, or those licensed for Zakat and Tax Services: 7 hours (7 points)" and "Non-practitioner Full Members, holders of fellowship, or technical employees: 4 hours (4 points)". No qualifying sentence accompanies them. We do not know what period they cover or what subject they relate to, and we are not going to guess. What they do establish is that SOCPA treats hours and points as equivalent one for one in at least those two cases.

No multi-year cycle appears anywhere we could read. "Annually" is the only period given, and the year's start and end are not stated — not even whether it is a calendar or Hijri year.

Formal and informal, with no allocation between them

SOCPA's e-service page for adding points asks the member to choose the nature of the activity as formal or informal, and elsewhere describes one activity as "a form of informal learning". So the split exists and those are SOCPA's own terms — not structured and unstructured, not verifiable and unverifiable.

No allocation, minimum or cap between formal and informal points is published on anything we retrieved. A member can therefore establish that the categories exist without being able to establish what proportion of the 65 may come from each.

The consequences are published, and they are short

SOCPA's practitioner and non-practitioner full member pages give the ladder in two steps. "If a member does not comply with CPE requirements, his/her membership shall be suspended." And then: "their membership will be cancelled within a year of being suspended" if the matter is not resolved. Reinstatement is available once the cause is resolved and the requirements of the membership regulations are met.

Suspension to cancellation inside twelve months is a fast ladder by international standards, and it is the one piece of SOCPA's administration that is clearly stated.

The full list of what is not publicly established

We are setting these out explicitly because each is a place where a confident sentence would be an invention. For SOCPA members, the following could not be established from any retrievable source: the instrument that creates the obligation, by name, number or date; any mandatory subject; any ethics requirement whatsoever; the reporting or declaration deadline; the start and end of the reporting year; any formal or informal split or cap; any record retention period; any monitoring, verification or audit process beyond the instruction to "attach CPE related documents that proof your hours"; any sample rate or compliance statistic; and any exemption ground at all.

Note what the ethics item means. We are not saying SOCPA has no ethics requirement. We are saying that a SOCPA member cannot find one published, which is a different and in some ways more useful finding. The same distinction applies to the exemptions: a member who falls ill has no published route to relief, whether or not one exists in the unretrievable internal regulations.

SOCPA is a full IFAC member, established in 1992 and admitted in 1993, and is assessed as "Sustain" on the standard-setting obligation covering continuing development. That assessment is worth putting beside the list above, because it carries the same lesson as the Nigerian case: an international alignment assessment is a statement about the shape of a requirement, not about whether the member who has to meet it can find out what it is.

Source for the points figures: SOCPA's membership page, last updated 28 July 2021.