Identifying Your CPD Requirements

Members answering the CPD question on their Annual Return or selected for a CPD record review often have queries about the operation of the rules.  Full details of the regulations and associated guidance is available on the ATT website CPD Regulations and Guidance.

This page provides further guidance and some frequently asked questions on identifying and understanding your CPD requirements.

For those working in tax, please see here for some reminders of recent and upcoming headline tax changes. Whether updates on these topics are relevant to your CPD requirements will depend upon if they are related to your working role and duties.

If you have any further queries on your CPD requirements, please contact us at [email protected].

FAQs on CPD requirements, record keeping and what records should include:

Q.1 What activities count as CPD?

CPD should cover the topics needed to maintain and develop skills and competencies appropriate to the member’s duties. CPD will not relate only to tax technical material and if members are within the scope of the regulations because of use of the designations it may be the case that they have no tax technical CPD requirement. Topics to be considered for inclusion:

  • Tax technical areas which the member is involved with eg personal tax, corporation tax, R&D etc
  • General tax technical awareness courses to ensure awareness of other areas of relevance
  • HMRC material
  • Professional standards material e.g. Professional Conduct in Relation to Taxation
  • AML and economic crime
  • Professional skills and behaviour e.g. report writing
  • Cyber security and GDPR e.g. ICO website material
  • Equality, diversity and inclusion
  • Practice management e.g. employment law

CPD can be accessed in a number of different ways and does not need to always be undertaken in person. For example, there has been much more use of online webinars and resources (triggered by the COVID pandemic). Use of a wide range of sources of CPD material will continue to be important moving forward. Information on sources of CPD is available on the CIOT website here and the ATT website here. Some examples of the ways of undertaking CPD are set out below:

  • Branch webinars or meetings.
  • Conferences, seminars, workshops, discussions at committee meetings and similar events organised by CIOT or ATT and its branches or similar training organised by other professional bodies, professional firms and companies.
  • Learning media including podcasts and computer-based training packages (such as webinars and e-learning).
  • Learning at work, such as firms’ training meetings, coaching and mentoring.
  • Technical discussions on client matters, new legislation and case law.
  • Studying for a relevant further qualification.
  • Developing and presenting relevant training material.
  • Writing books, articles and reviews.
  • Reading technical journals such as Tax Adviser.
  • Researching the answer to a technical query.
  • Reading material relevant to the member’s role such as anti-money laundering guidance or professional standards material e.g. Professional Rules and Practice Guidelines and Professional Conduct in relation to Taxation.
Q.2 Are there any ‘minimum hours’ CPD requirements?

There are no longer ‘minimum hours’ nor ‘structured versus unstructured’ CPD requirements. The key requirements are indicated in the CPD Regulations and Guidance and these are:

  • Members are required to perform such CPD as is appropriate to their duties.
  • Members are required to keep a record of all CPD undertaken.
  • There is no prescribed form for keeping the CPD records.
  • Members should be capable of demonstrating from their records that they understand and comply with the regulations.
Q.3 I am not working in tax. What are my CPD requirements?

CPD is the mandatory requirement to maintain and develop skills and knowledge necessary to carry out professional and technical duties competently throughout the member’s working life,

It applies to all members of the Chartered Institute of Taxation (CIOT) and the Association of Taxation Technicians (ATT) and Advanced Diploma in International Taxation (ADIT) affiliates who: 

1. Provide tax compliance services, advice, consultancy or guidance in tax including, without limitation, those in private practice, the public sector commerce, industry or not for profit sector; 

2. Do not fall into paragraph 1 above but who use the designation(s)*; CTA, CTA (Fellow), ATII, FTII, Chartered Tax Adviser, ATT, Taxation Technician, ATT (Fellow), Taxation Technician (Fellow), ADIT affiliate or International Tax Affiliate of the Chartered Institute of Taxation.
 

Members coming within the scope of the regulations are required to perform such CPD as is appropriate to their duties. Therefore, CPD records for those not working in tax would relate to their non-tax duties.

If you do not use your designation and do no tax related work whatsoever then you will be outside the scope of the regulations.

See some examples below:

Example 1. No tax work, email sign off with letters ATT, ATT (Fellow) etc, or listed on website as ATT qualified

An ATT member who works in the banking industry, who is not undertaking any tax work and whose email sign off includes the letters ATT is within scope of the CPD regulations. They are required to undertake and record CPD to ensure they are carrying out their duties competently.

This means the CPD required will be non-tax related as their working duties are non-tax related.

Example 2. No tax work, not using ATT designation

An ATT member who works in the banking industry, who is not undertaking any tax work and doesn’t indicate they are a ATT anywhere on their working records. They are NOT within scope of the CPD regulations.

Example 3. Working in banking, small amount of tax work

An ATT member who works in the banking industry, and who undertakes any amount of tax work (however small) as part of their duties is within scope of the CPD regulations for all the work they undertake.

This means the CPD required will be both tax and non-tax related as they have mixed duties.

 

Q.4 I am a member of another professional body with CPD requirements. Do I have to undertake more CPD?

It is very likely that compliance with the CPD requirements of a member’s other professional body and in house training and development programmes operated by employers will count towards, and possibly fulfil, the CIOT and ATT requirements.

It is important that members review the position and ensure they meet the requirements of both the other professional body of which they are a member and the CIOT and ATT requirements. Where a member works in a predominantly tax related role they should ensure that sufficient CPD is undertaken so their tax knowledge is appropriate to the role they are undertaking.

There is no prescribed form for keeping ATT CPD records, though you may wish to download the CPD form from the ATT website as this covers what we expect to see in good records. If you are a member of another professional body, or work for a business which requires you to keep CPD records in a prescribed format then you may use those records, suitably adapted if necessary.

For ATT members who are also subject to the ICAEW CPD Regulations (which changed in 2023) we have some guidance here to address common questions.  

Q.5 I will be on a career break for the next 6 months to a year. What are my CPD requirements?

Members may suspend CPD when they are temporarily not working. However, ATT encourages members to meet the CPD requirements on a voluntary basis as a means of ensuring that they keep up to date, where appropriate.  This is particularly important where the member will be returning to a role where tax knowledge is required. Examples of temporarily not working are: On extended leave due to family, personal, or health circumstances (eg on maternity leave, or dealing with illness), on a career break, not working or on sabbatical leave. 

Q.6 I am retired but providing some free of charge tax services to friends and family or a local charity. Do I need to do CPD?

The CPD Regulations and Guidance were updated in 2022 with some minor changes effective from 1 January 2023. These include clarification of the requirements for pro bono work and retired members:

Example 4. Fully retired, no tax work at all, either pro bono or paid for.

You were fully retired for the calendar year with no paid work of any kind (tax or otherwise). You provided no tax services whatsoever including no pro bono (free of charge) services. You are exempt from the CPD regulations. 

Example 5. Retired, some pro bono tax work undertaken and still using the designatory letters.

You were fully retired for the calendar year but were providing pro bono tax services (free of charge) to family members and a local charity. You were using your letters ATT in your email signature. You are within scope of the regulations and are required to undertake appropriate CPD in respect of these services.

 

Therefore, if CPD is not being undertaken you must not hold yourself out as a member by use of the designations (apart from those who are honorary members).  Where the designations are not being used, members are still required to consider whether CPD would be beneficial for the protection of the recipient of the services and the member must be transparent  with those they provide services to where no CPD is being undertaken.

 

Members should refer to the updated regulations and guidance to ensure they are clear on the changes now in place.

Q.7 What records do I need to keep?

The regulations state that ‘Members are required to perform such CPD as is appropriate to their duties.’  When completing your CPD record please link the CPD undertaken to the requirements of your role.

Members are required to keep a record of CPD undertaken for the current year, and the three preceding years. We would expect records to show:

  • The date CPD was undertaken
  • Details of learning or activity (including course title and provider where relevant)

There is no prescribed form for keeping the CPD records, though we recommend that you download the CPD form from the CIOT or ATT websites as this covers what we expect to see in good records. However, if you are a member of another professional body, or work for a business which requires you to keep CPD records in a prescribed format then you may use those records, suitably adapted where necessary.

We expect members to be able to explain why the level of CPD undertaken is appropriate.

Q.8 How regularly should I maintain my CPD records?

We recommend that you regularly update your CPD record throughout the year. This is particularly important if where you work does not have a system where CPD activity is logged, for example via timesheets. You can be asked to provide your CPD record for the current year plus the three previous complete calendar years.

When reviewing records, it is sometimes evident that a CPD record has not been kept up to date over time and has been ‘recreated’ at some point afterwards, usually in response to a record request for those selected as part of the annual audit of CPD records. Such records can be lacking in detail or do not include the range of activities we would expect to see. Poor records and record keeping may give rise to further follow up action being required of a member, particularly where insufficient record keeping makes it difficult to assess if a member is meeting their requirements.

Q.9 What does Professional Standards CPD learning involve?

Members should include an element of professional standards material in their annual CPD, where this is relevant to their role.

Professional Rules and Practice Guidelines

You will need to consider your requirements to comply with the following fundamental principles as set out in our membership Professional Rules and Practice Guidelines (PRPG):

  • Integrity
  • Objectivity
  • Professional competence and due care
  • Confidentiality
  • Professional behaviour

Professional Conduct in Relation to Taxation

Those working in taxation must also meet these principles and associated guidance as set out in Professional Conduct in Relation to Taxation (PCRT) and meet the five standards for tax planning.

Other Membership Professional Standards Considerations

Please visit the Professional Standards section of the ATT website addressing the many areas that involve professional standards matters, for example the holding of professional Indemnity insurance, the use of engagement letters, or the handling of complaints.

Ongoing adherence to professional standards requirements seeks to ensure:

  • Protection of the public
  • Protection of the reputation of the CIOT, ATT and ADIT Affiliate status and the tax profession generally
  • Protection of the member’s professional standing 

Members must adhere to professional standards requirements and should review the professional standards and AML sections of the website (as relevant to their role). Watching the webinars provided and attending branch events also assists members in keeping up to date with requirements.

Q.10 Should I be recording Anti Money Laundering (AML) training on my CPD record?

If you are working in practice, either as an employee, a consultant or a principal in a firm, or if you are working in a relevant industry (eg banking) you will have AML training requirements as set out in The Money Laundering, Terrorist Financing & Transfer of Funds (Information on the Payer) Regulations 1017 (as amended). For those working in the accountancy sector, which includes taxation services, Chapter 8 of AML Guidance for the Accountancy Sector provides information and guidance on AML training requirements.

We would expect to see AML training received and any relevant learning undertaken to be included in a member’s CPD record.

Q.11 I have a query not addressed above, what should I do?

There are a range of further common question and answers set out in section 10 of the CPD Regulations and Guidance. If, after reviewing this section, your query remains unanswered please contact us at [email protected].