ICAEW CPD Changes – FAQ for members of CIOT and ATT impacted by these changes

Not at present.  We last reviewed the CPD Regulations and Guidance in 2022 with minor amendments made coming into effect from January 2023. An ongoing assessment is undertaken as to whether the regulations and guidance remain relevant to our aims and membership. This work is led by the Professional Standards Committee and associated CPD working party and we take into account feedback from our members and third parties. We also review the results of our annual check of member records.

Whilst the ICAEW has now re-introduced an hours requirement to give a base line to their members, they continue to adopt the reflective approach to CPD (RAID - Reflect, Assess, Impact, Declare) and the CPD undertaken to meet the hours requirements must be relevant to their members’ roles.

Our own approach is similar in that we suggest our members should plan for, take action to meet, and reflect upon their annual CPD requirements. All CPD undertaken must be relevant to a member’s duties. If our members do not work in tax but they use their membership designations (for example on their email footer) they are still required to undertake CPD. Those in a non-tax role therefore need to ensure their CPD is relevant to their area of work. 

Our members continue to indicate high levels of CPD learning and compliance with the CIOT/ATT CPD Regulations and we assess this through:

• The responses provided by members on their annual return.  The annual return is a membership requirement and provides information to us on their professional activities including compliance with a range of legal and membership requirements, including confirmation of compliance with the CPD Regulations;
• The results of the annual CPD check of a sample of member records.  

Whilst we no longer have ‘hours based’ CPD requirements many members continue to include this data in their records when selected to be part of our annual check.  We see that on average our members record more CPD hours than those being required by ICAEW following their CPD regulation changes:

These annual return and CPD check results indicate good levels of compliance. At present therefore we have not identified a need to return to a solely hours-based approach.

Those who are members of more than one professional body are required to meet the requirements of each professional body. Joint members, or CIOT/ATT members affected by virtue of their connection to ICAEW for regulatory purposes (see FAQ 4 below), must ensure they are up to date on the changes and are undertaking CPD activities, including record keeping, in line with those requirements otherwise they risk disciplinary action by the ICAEW.

A member will need to assess if meeting the ICAEW requirements also meets the CIOT/ATT regulations as per the CPD Regulations and Guidance section 10.7, excerpt reproduced here:

We provide template CPD forms for use here, but we also accept CPD records held in a wide variety of formats including other professional body forms or a firm’s standard form. Please note that at a minimum the CIOT/ATT would expect a record to show:

• The date CPD was undertaken.

• Details of learning or activity (including course title and provider where relevant).

Members are expected to be able to explain why the level of CPD undertaken is appropriate.

Provided the CPD undertaken to meet ICAEW requirements is relevant to the member’s role this will also meet CIOT/ATT requirements and we would not expect a member to have to maintain two separate records for the two bodies.

Final classification as to whether CPD learning provided by CIOT or ATT is verifiable or non-verifiable for ICAEW CPD purposes remains with the ICAEW.  Please see ICAEW’s verifiability guidance for detailed information on what is classed as verifiable and how that can be evidenced, as well as for more information on the different levels of CPD hours requirements. Broadly, for a CPD activity to be verifiable there must be evidence of its completion that is:

• Objective - fact based rather than based on personal perspectives.
• Corroborated - can be confirmed to be accurate; and
• Retained - documented and stored in an observable format.

Our members undertake a lot of technical research and reading as part of regular ‘on the job’ CPD and these are likely to be assessed as follows:

• Technical research: Verifiable where the results of that research can be produced in presentations, reports, file notes or similar documents.
• Technical reading: Only verifiable if the reading can be evidenced. Otherwise, would count as non-verifiable CPD if it is relevant to the learning needs of your role. 

CIOT or ATT webinars can be recorded as verifiable CPD for ICAEW’s purposes if there is proof of participation or attendance (for example a registration email for a webinar or an email confirming attendance). We are currently looking into our IT systems so that attendance at our Professional Standards and AML webinars can also be verified.

ICAEW have provided the following guidance on this subject:

Only ICAEW members, and other individuals regulated by ICAEW are within the scope of their CPD regulations. The other regulated individuals include:

• a responsible individual for audit,
• a key audit partner for local public audit,
• an insolvency practitioner,
• a probate authorised individual, and 
• a licensed practitioner under the licensed practice scheme.

Any individuals who are not ICAEW members, and who also are not an individual regulated by ICAEW are not within scope of their CPD regulations.

It is the case that ICAEW regulated firms remain subject to the requirements to employ staff competent to undertake their roles, so some ICAEW compliance or assurance reviews may look at all staff CPD records, but again for individuals who are not ICAEW members and not regulated by ICAEW, we understand that these would not need to meet the specific ICAEW hours based requirements.