38. Verification of competence for output-based systems is an objective assessment that competence has been developed or maintained. Verification is to be provided by a competent source in a position to confirm that the competence has been developed and maintained using a valid method or technique. The assessment should clearly identify the outcome or competence achieved, which may be the result of a particular learning activity or an extended development program that involves numerous learning activities, the achievement of performance outcomes (e.g., from the work environment) or other means (e.g., professional re-examinations).
39. The evidence may take many forms. Examples of verification can be found in the Appendix to this IES.
Combination Approach
40. Member bodies implementing a combination of input- and output-based approaches should follow the principles of input and output systems, as applicable, set out in this IES.
41. There are several alternatives for adopting a combination approach to CPD. For example, member bodies may choose to:
(a) Adopt an input-based approach for some sectors or other grouping of members and an output-based approach for others;
(b) Use the concepts of both input- and output-based systems, whereby input-based learning units contribute to the output competences being measured for a portion of the knowledge areas in a predominantly output-based system;
(c) Allow professional accountants who may not meet the input-based learning units requirement to provide verification that competence has been developed and maintained;
(d) Specify a certain number of learning units as an indication of likely effort required to achieve competence and monitor this together with verification of competence achieved as a result of the learning activities; or
(e) Introduce a combination approach before moving towards a comprehensive output-based system.
Monitoring and Enforcement
42. Member bodies should establish a systematic process to monitor whether professional accountants meet the CPD requirement and provide for appropriate sanctions for failure to meet the requirement, including failure to report or failure to develop and maintain competence.
43. In designing their approach to monitoring, member bodies may consider which of their members have the greatest responsibility to the public or pose the greatest risk to the public and adopt more rigorous monitoring for those operating in high risk roles.
44. A monitoring process could require professional accountants to periodically:
(a) submit a declaration as to whether they meet their ethical obligation to maintain knowledge and skill to perform competently;
(b) submit a declaration as to compliance with any specific CPD requirements imposed by the member body; and/or
(c) provide evidence of learning activities or verification of competence developed and maintained.
45. Reporting cycles of greater than five years would be unlikely to meet the objectives of this IES.
46. Other monitoring processes could involve:
(a) Auditing a sample of professional accountants to check compliance with CPD requirements;
(b) Including the review and assessment of learning plans or CPD documents in practice inspection programs; and/or
(c) Requiring public practice employers to include CPD programs and effective monitoring systems in their quality assurance programs and to track CPD activities as part of their time recording systems.
47. Member bodies need to require professional accountants to maintain evidence for a sufficient period of time to support the prescribed reporting requirements.
48. Verification needs to be in the form of documentation that can be provided easily to the member body for review purposes. Examples are provided in the Appendix to this IES.
49. A system of mandatory CPD will operate effectively and in the public interest only if professional accountants who fail to comply with the requirement are brought into compliance on a timely basis or, if they persist in willful noncompliance, are appropriately sanctioned. Member bodies are encouraged to determine punitive sanctions after considering the legal and environmental conditions in their countries. Some member bodies may have the legal authority to expel non-compliant professional accountants or to deny the right to practice.
Publication of the names of professional accountants who willfully fail to comply is one option to be considered in this process. This can act as a general deterrent for professional accountants and provides a clear signal to the public of the profession’s commitment to maintaining competence.
50. The initial steps taken to address non-compliance are likely to focus on bringing the professional accountant into compliance within a reasonable period. Care needs to be taken to strike a balance between a sanction that, in substance, amounts to permitting a professional accountant to defer or avoid compliance with the CPD requirement and one that is excessively punitive.