I failed to report completion of my CPD Requirements, what now?
The life of a CPA can be extremely busy. Tasks can pile up at certain points in the year. This can lead to some CPAs to find for one reason or another that they were unable to complete their yearly CPD requirements. What does this mean, what are the potential consequences, and when should they inform their CPA association to figure out next steps and potentially create a plan of action for making up all required CPD hours?
What if I fail to Report CPD:
If you fail to report completion of your required CPD hours, you will face potential financial penalties. Failure to further report and pay these penalties will result in actions being taken including but not limited to your license being suspended or revoked. There will be ample notice and opportunity to remedy your situation before these actions are taken.
What if I make a False Declaration:
Making a false declaration means declaring yourself in compliance when you in fact did not complete some or all of your CPD requirements.
Making a false declaration is a serious transgression and can have significant consequences. If you make a false declaration, you will be referred to the registration committee. They will take action including potentially suspending or canceling your CPA status.
Reporting your Non-Compliance:
If you are not going to be able to complete your 1 or 3 year CPD requirements on time you must declare your non-compliance to your provincial body. You should begin this process as soon as you know you will not be able to complete your requirements.
You will then need to put together a plan detailing how you will get yourself back into compliance by the end of the next reporting period. This must include:
- Your completed verifiable and unverifiable hours
- Why the CPD requirements were not met
- A plan of action on how you will bring yourself back into compliance
- Any circumstances that will prevent you from returning to compliance
By the end of the next reporting period, you must have both made up the hours you didn’t complete in the previous year(s) and completed your required hours for the current year. If you have successfully achieved this, you are fully in line with your CPD compliance.
Provinces have different time frames on how many days you have to submit a plan and how long you have to complete the plan. If you need further clarification contact your provincial CPA body or consult their CPD requirements policy.
Specific CPD compliance reporting rules by Province
CPD Non-Compliance Rules Ontario (ON):
A Member who indicates in their annual compliance declaration that the continuing professional development requirements were not complied with shall file within 14 Days of the compliance declaration a plan of action in the prescribed form detailing how the Member intends to complete the required continuing professional development, and failure to do so will result in an immediate administrative suspension.
A Member shall complete the steps outlined in the plan of action filed and file with the Registrar the prescribed form attesting to that completion within 120 Days from the Day the plan was filed, and failure to do so will result in an immediate administrative suspension. After receiving the attestation, the Registrar shall review it and the plan of action to determine whether the plan is sufficient to satisfy completion of a Member’s continuing professional development requirements, and to determine whether the plan has been completed. If the Registrar is satisfied that the plan is sufficient and has been completed, the Member shall be deemed to have complied with the continuing professional development requirements for the reporting period
CPD Non-Compliance Rules BC/Yukon:
If a member fails to deliver an annual compliance report, or fails to comply with the applicable requirements of the Continuing Professional Development Program, by the further deadline prescribed under Bylaw 601, the membership of the member is suspended until the member
- delivers an annual compliance report,
- satisfies any applicable outstanding requirements of the CPD Program. And
(c) pays any administrative fee prescribed by the board.
CPD Non-Compliance Rules Alberta (AB):
If a declaration of non-comply is made, you will be asked to provide information regarding why your requirements were not met and your plan to bring yourself into compliance by the end of the next reporting period.
CPD Non-Compliance Rules Quebec (QC):
Failure to comply with the obligation to declare training hours may result in the suspension, limitation of the right to exercise professional activities or even removal from the roll of the Order, or even the suspension or revocation of the public accountancy permit for holders of this permit.
A fee of $175 is imposed on members who do not work the minimum number of hours required for the year or the reference period ending on August 31 or who do not declare the minimum number of hours required by the regulations. no later than September 30 of each year.
CPD Non-Compliance Rules Manitoba (MN):
Under CPA Manitoba Bylaws, non-compliance with CPD requirements can lead to suspension and ultimately cancellation of membership.
CPD Non-Compliance Rules Saskatchewan (SK):
CPAs who do not meet the minimum requirements for CPD are required to address the deficiency in the subsequent calendar year. There are two ways a CPD deficiency can be addressed:
- Prior to Spring Renewal (January 1 to March 31): If the CPA has obtained sufficient hours to make up the deficiency prior to March 31 of the subsequent year, they can update their CPD hours in the member portal and email monitoring@cpask.ca with a request to apply these hours to address the previous year’s deficiency. If approved, the hours will not be adjusted back.
- During Spring Renewal (April 1 to April 15): The CPA may choose to submit a declaration of non-compliance during Spring Renewal and must commit to addressing the prior year’s deficiency by the end of the calendar year. The minimum requirements of the calendar year must include both the CPD intended to be taken to address the deficiency from the previous cycle and the current year’s requirements (e.g., if a CPA is short 5 hours, the CPA will need to obtain sufficient CPD hours to address the 5-hour shortfall plus the 20-hour requirement for the current year).
CPAs who do not meet the minimum requirements for CPD for two or more consecutive calendar years will be required to submit a formal CPD plan for review by the Registration Committee. In reviewing the formal CPD plan, the Registration Committee may choose to restrict or suspend a CPA’s registration. All restrictions and suspensions are published on our website and newsletters.
CPD Non-Compliance Rules New Brunswick (NB):
If you did not complete the minimum annual CPD requirements by the end of the calendar year, you will need to complete the CPD Plan, which sets out the steps you will take to complete the CPD requirements.
The CPD Plan should be sent to CPA New Brunswick before the March 31 deadline for the Registrar’s approval.
Non-compliance with CPD requirements can lead to suspension of your membership.
CPD Non-Compliance Rules Nova Scotia (NS):
A member who fails to complete the minimum required hours of continuing professional development prescribed by Sections 398 or 399 shall be referred to the Professional Development Committee, which may take one or more of the following actions:
(a) Waive a portion or all of the continuing professional development requirement;
(b) Stipulate the time frame and manner in which the member must complete any deficiency;
(c) Make a report to the Chief Executive Officer recommending that the Chief Executive Officer refer the fact of the member’s failure to complete the minimum required hours of continuing professional development to the chair of the Complaints Committee which referral shall be considered a complaint for the purposes of these By-Laws; or
(d) Make a report to the Chief Executive Officer concerning the member’s failure to complete the required hours and recommend that the member’s registration should be suspended until certain action identified by the Professional Development Committee is taken by the member.
CPD Non-Compliance Rules Newfoundland and Labrador (NL):
If you did not meet the annual CPD requirements, and plan to do so, you must complete and submit a CPD Plan to Remedy.
Newfoundland and Labrador CPD Rules
CPD Non-Compliance Rules Prince Edward Island (PE):
In the event that a member is non-compliant by failing to file their continuing professional development report by the January 31st deadline, a notice will be sent within 45 days notifying the member of noncompliance and that the member has 30 days from the date of the notice to rectify the situation or risk being suspended. If a response is not received within the 30 day period, the board may immediately suspend the member and the member will be notified of the suspension in writing. In the event of non-compliance with the continuing professional development reporting requirements a $100 late reporting administration fee may be payable to CPA PEI
CPD Non-Compliance Rules Northwest Territories/Nunavut (NT/NU):
If members fail to meet the CPD requirement in a particular year, the member will be subject to a noncompliance fee of $300 and a plan of action form or an exemption request in the prescribed form must be filed within 60 days of the CPD deficiency being declared by the member. Only one plan of action will be accepted in each three-year CPD cycle.
The plan of action shall indicate that the member agrees to complete additional CPD in the proceeding year to reduce any deficiency from the minimum verifiable and unverifiable CPD requirement for the reporting period. The plan of action shall describe how the member intends to achieve this in an appropriate level of detail so that the plan may be evaluated by the CPA NWT/NU Board. The plan of action must be accepted by CPA NWT/NU and members agree to notify CPA NWT/NU once the required CPD has been completed.
Failure to submit the plan of action form within 60 days or complete the approved plan of action within the proceeding CPD declaration year, will result in membership suspension. In order to apply for reinstatement, the applicable reinstatement fee and compliance declaration attesting to having completed the required amount of CPD must be provided to CPA NWT/NU. CPA NWT/NU bylaws regarding reinstatement also apply.
Members who did not comply and had to submit a plan of action will be subject to an automatic audit in the following year.
TL;DR
Non-Compliance and it’s associated consequences can seem scary, but they can be dealt with fairly easily if you make a concerted effort to make up any hours. There is generally ample time an opportunity for you to get back in good standing if you are honest, forthcoming and proactive about reporting your non-compliance.
If you want a boost in getting your verifiable CPD hours, LumiQ is offering 5 free CPD hours to all Canadian CPAs. You will receive access to our library of over 600 episodes of engaging conversations with business leaders and interesting stories in the world of accounting. You can sign up here to claim your free hours.
