Verifiable CPD for Canadian CPAs: The Number Is 60, Not 4

Ask a Canadian CPA which part of their CPD must be verifiable and most will name the four ethics hours. The ethics requirement is four hours. The verifiable requirement is sixty.

That gap — between the number people remember and the number the regulation sets — is the most common cause of a CPD record that looks complete and fails an audit.

The rule, in the regulation's own words

Ontario's Regulation 7-2 puts it as a percentage rather than a figure, which is part of why it gets missed. Section 4 provides: "At least 50 percent of both the annual and triennial period hours set out in section 2 shall consist of Verifiable continuing professional development."

Apply that to the harmonised 120-hour, three-year cycle and the 20-hour annual minimum, and you get:

• 60 verifiable hours per three-year cycle
• 10 verifiable hours per year
• Of which 4 hours, across the cycle, must be professional ethics

CPA Alberta states the same thing as a flat number: the CPD requirement for the three-year cycle is 120 hours, of which 60 hours must be verifiable learning. CPA Manitoba publishes the internal split explicitly — over the rolling three calendar year cycle: verifiable 56, verifiable professional ethics 4, other CPD 60, for a total of 120.

Manitoba's arithmetic is the clearest statement of the structure. The four ethics hours sit inside the sixty verifiable hours. They are not an addition to them, and satisfying them does not advance you towards the other fifty-six.

CPA Saskatchewan's exemptions chart confirms the same verifiable minimums — 60 per cycle and 10 per year — and is in fact the figure we could verify most reliably for that province.

What makes an hour verifiable

Verifiable does not mean accredited, and this is where the Canadian framework differs from what practitioners often assume from other jurisdictions.

No province requires an approved provider. CPA Manitoba states it directly: "CPA Manitoba does not accredit course providers." Learning must be relevant to the member's role, with documentation retained.

Ontario defines the test as evidential rather than institutional: "It means you must have documentation from an independent provider to confirm your professional development hours." Its list of acceptable evidence is practical — course invoices, certificates of completion or official transcripts, provider or employer confirmation, and attendance records.

So the question to ask of any activity is not "is this provider recognised by my regulator" but "can an independent third party confirm I did this, and is the content technical and relevant to my role".

What does not count, which is a longer list than people expect

Ontario draws the exclusions sharply:

• "Volunteering does not generally count as CPD hours"
• Networking and social functions generally do not count
• "Exclusively taking language courses would not count as professional development"
• Ethics activities "must go beyond an awareness of the rules, standards or guidelines"

That last one is a quality test, not a format test, and it is the one most likely to be applied against a cheap compliance module. Reading a summary of the Code is awareness. Working through its application is not.

Manitoba adds a format restriction that no other province imposes: "Self-study will not qualify as verifiable professional ethics." A Manitoba CPA cannot discharge the four ethics hours through an unproctored self-study module, however well documented.

The audit evidence says hours are not the problem

CPA Ontario is the only one of the four provinces publishing CPD audit outcomes, and its Regulatory Report 2026 is instructive. The audit covered over 3,000 members, including 10% of public accounting licence holders, with 84% compliance and 1% suspensions.

The five most common reasons members received further direction were: lack of technical content, non-qualifying committee membership, insufficient detail, inappropriate content, and work activities used as CPD.

Read that list again. Only one of the five is about quantity. Four are about the character of what was claimed — content that was not technical, a committee seat that did not qualify, records too thin to assess, and day-job activity logged as development. A member can reach 120 hours and 60 verifiable hours and still be directed to complete more, which Ontario's report confirms is what "other regulatory action" means in practice: completion of additional verifiable CPD hours to rectify deficiencies.

The practical implication is that the sixty-hour figure is a floor you should clear with documented margin, not a target to land on exactly.

Quebec runs a different model entirely

If you have members in Quebec, almost none of the above transfers. The Ordre des CPA du Québec operates under Quebec's Code des professions, and the differences are structural rather than cosmetic:

• The reference period is fixed, not rolling — currently 1 September 2025 to 31 August 2028
• 120 hours per period, but a 25-hour annual minimum rather than 20
• Self-study is capped at 15 hours per year and 45 per period. The other provinces simply allow up to 50% unverifiable; Quebec sets a hard ceiling
• Four structured ethics hours, plus a mandatory one-time three-hour course on the CPA Code of ethics
• Public accountancy permit holders need 60 structured hours per period and 15 per year in public accounting, with the four ethics hours counting inside the 60
• Completion by 31 August, declaration by 30 September
• Sanctions extend to suspension, limitation of the right to practise, or striking from the roll, plus a $175 charge for members who fall short of the minimum hours

The self-study cap is the one to watch commercially. A learning plan built on 50% unverifiable content is compliant in Ontario and non-compliant in Quebec.

Where to start

If you are reconstructing a CPD record, work backwards from the verifiable figure rather than the total. Sixty hours of independently documented, technical, role-relevant learning across three years is the binding constraint; the remaining sixty can be reading, research and informal development, which most professionals accumulate without trying.

And check your province before you check your hours. Our guide to CPA CPD deadlines and penalties by province sets out the reporting dates, the penalty scales and the four different exemption tests, including the Manitoba ethics restriction. For the pre-qualification stage, see CPA Canada's PEP and the CFE explained, and for why Canadian and American materials use different vocabulary for the same obligation, CPE versus CPD.