# IAA CPD requirements: scheme, plan and records

> The UK IAA CPD scheme sets no fixed hours. Who must comply, what to plan and record, when the IAA checks it, the sanctions, and a template to adapt.

Guide · Immigration compliance · By Syed Husnain Khalid · Published 8 October 2026 · Last checked 8 October 2026
Drafted with AI. Each claim was checked against the primary sources listed below by AI on 8 October 2026; a person has not reviewed it yet.
Canonical: https://vexralabs.com/insights/iaa-cpd-requirements

Short answer

The UK Immigration Advice Authority (IAA) sets **no minimum number of CPD hours**. Code 4.4 of its Code of Standards 2024 requires advisers to demonstrate compliance with its continuing professional development (CPD) scheme. Each registered organisation must consider its needs, plan CPD, evaluate the outcomes and keep records with supporting evidence for every authorised adviser.

This guide is for the owners and advisers of organisations registered with the IAA, and for applicants preparing a first registration. CPD matters early: the IAA aims to audit a newly regulated organisation within 12 months of approval, and its audit letter can ask for each adviser’s CPD plan and record. We build Filyst, case software for immigration firms, and it has no CPD module, so the template here is a plain table. The sections cover what the scheme is, who it applies to, the hours question, what to plan and record, when the IAA checks, and what follows if the evidence is missing.

**Diagram: The IAA CPD cycle for one authorised adviser.** Five steps repeat each year. Consider: identify the skills and knowledge the adviser and the organisation need. Plan: write a learning and development plan with objectives and dates. Do: complete the learning. Record: write the learning and development record and keep supporting evidence. Review: meet at least once a year, evaluate whether outcomes were achieved and agree the next plan.

*The IAA scheme asks for a considered plan, completed learning, a record and a yearly review. It sets no hours.*

## What is the IAA CPD scheme?

The IAA CPD scheme is the Immigration Advice Authority’s set of requirements for how registered advisers keep their knowledge and skills current. It is principle-based: it looks at the outcomes of learning, and it puts the responsibility on advisers and organisations to show they are staying fit and competent.

Three Codes under Principle 4 of the [Code of Standards 2024](https://assets.publishing.service.gov.uk/media/6776b2ef6c34906cc84c9499/IAA_Codes_of_Standards_2024.pdf)sit behind it. Code 4.1 says you must be fit to provide immigration advice or services. Code 4.3 says you must maintain the required level of competence and keep your immigration and asylum knowledge current and of sufficient depth for your role. Code 4.4 says you must be able to demonstrate that you are compliant with the Commissioner’s continuing professional development requirements. The Code uses “the Commissioner” for the Immigration Services Commissioner, their deputy, their staff and any agent acting for them. The 2024 Code took effect on [1 September 2024](https://www.gov.uk/government/publications/oisc-code-of-standards-commissioners-rules-2012).

The requirements themselves are in the IAA’s [CPD Scheme and Practice Note Booklet](https://assets.publishing.service.gov.uk/media/682c573fa4a41a5b3eb00c72/Continuous_Professional_Development__CPD__Practice_Note_2025.docx), which the Guidance Notes call the CPD Practice Note. It is published on the [Continuing Professional Development Scheme page](https://www.gov.uk/government/publications/oisc-continuing-professional-development-scheme), last updated on 21 May 2025, alongside two Word templates: a learning and development plan and a learning and development record. The [Guidance Notes to the Code](https://assets.publishing.service.gov.uk/media/66a8b9eda3c2a28abb50d95d/Guidance_Notes___Code_of_Standards_2024.pdf) summarise the scheme under Code 4.4 and refer readers to the booklet. Guidance Notes help to interpret the Code but are not provisions of it.

The scheme page’s address still contains “oisc”. Our post on [OISC vs IAA](https://vexralabs.com/insights/oisc-to-iaa-changes) explains the older name, which matters here only because searches for the old scheme lead to the same document.

## Who must do CPD, and who is exempt?

**All registered advisers**must demonstrate that they use CPD to remain fit and competent, from the date of their registration. The booklet says so under “Who has to comply with the scheme?”. The planning and record duties fall on the registered organisation, which is the business registered with the IAA, for each authorised adviser it employs.

The booklet lists three groups who do not have to comply:

- Advisers who are qualified to provide immigration advice and services in the UK by a Designated Qualifying Regulator or Designated Professional Body.
- Those exempt by Ministerial Order under section 84(4)(d) of the Immigration and Asylum Act 1999.
- Authorised advisers on maternity leave and long-term illness.

The third exemption comes with two duties. The registered organisation is responsible for telling the Commissioner about any authorised adviser on maternity leave or long-term illness, because this is a change of circumstances under Code 3.6. When the adviser returns, the booklet says the organisation must evaluate their training needs and make CPD plans before they start advising again. Section 9.5 of [IAA registration explained](https://www.gov.uk/government/publications/iaa-adviser-registration-explained/iaa-adviser-registration-explained) repeats the point.

## How many CPD hours does the IAA require?

**None is fixed.**The Guidance Notes on Code 4.4 say the scheme “is not prescriptive as to how much CPD activity should be undertaken by authorised advisers”. The booklet adds that each organisation can decide how much learning each authorised adviser does and in what format, as long as it contributes to the adviser remaining fit and competent.

The freedom has two limits. Learning must be relevant to the business and the work the adviser does, and the adviser must be able to demonstrate that relevance when the Commissioner asks. The Commissioner may also recommend specific areas to improve, for example after a competence assessment, a complaint investigation or an audit.

Annex A of the booklet describes formal, informal and blended learning. Its list of methods is not exhaustive and includes classroom, online and in-house training, conferences, webinars, reviewing GOV.UK and Home Office pages, reading from reputable sources, and supervision, coaching and teaching. Self-study counts as informal learning. The booklet strongly recommends that all learning come from reputable providers, and for informal learning it asks advisers to check the quality of the content themselves. The IAA’s own training videos, launched on [18 June 2026](https://www.gov.uk/government/news/iaa-launches-training-video-series-to-support-advisers), carry no certificate, and the IAA says advisers may log them as CPD.

## What must the CPD plan and record contain?

To comply with Code 4.4, the scheme requires a registered organisation to consider the needs of the organisation and its advisers, plan CPD activities that meet them, and evaluate whether the outcomes were achieved. The organisation must also keep records of each adviser’s CPD activities, supporting evidence, and records of CPD review meetings or planning.

| Scheme requirement | What to keep | Where the booklet says it |
| --- | --- | --- |
| Consider needs against the outcomes sought | A note of the skills and knowledge each adviser and the organisation need | Compliance with Codes 4.1, 4.3 and 4.4, (a) |
| Plan appropriate CPD activities | A learning and development plan per adviser for the year | Compliance with Codes 4.1, 4.3 and 4.4, (b) |
| Undertake the activities | A learning and development record with supporting evidence | Review and Inspection of CPD Records |
| Evaluate whether outcomes were achieved | The outcome noted in the record; a record of the review meeting | Compliance with Codes 4.1, 4.3 and 4.4, (c) |
| Show relevance to the work | A line tying each activity to the adviser's level, category or role | Relevant Learning and Development |

The IAA’s plan template asks five things for each item: what you need to learn, how you will achieve it, what support you need, what the learning objectives are, and the timescale. Its record template asks for the date of completion, what you learnt, why you did the learning, whether you met your objectives, and how you will apply it. Both open with the adviser’s name and number, the organisation’s name and number, and the CPD period.

The booklet says all CPD activity should be reviewed for each authorised adviser at least once a year, counted from the initial planning meeting. It suggests the start of the business year or the start or end of the registration year for that first meeting, and says delaying it unnecessarily is contrary to the spirit of the scheme. Annex A recommends SMART objectives: specific, measurable, achievable, relevant and timely. Sole advisers can adapt the process, and the booklet suggests they use networking with other advisers to discuss training needs.

## CPD plan-and-record template

This template merges the IAA’s plan and record into one table per adviser, so each planned item sits next to what happened. It is a starting point to adapt, not an IAA form. The IAA’s own two templates are on its [scheme page](https://www.gov.uk/government/publications/oisc-continuing-professional-development-scheme), and using them is equally valid.

Head the sheet with these six fields, which both IAA templates use:

- Name
- Adviser number
- Organisation
- Organisation number
- CPD period from
- CPD period to

Then add one row per learning need. The two example rows are invented to show the level of detail.

| Column | What to write | Example A | Example B |
| --- | --- | --- | --- |
| 1. What do I need to learn? | One specific gap | Changes to the family rules affecting current files | How to lodge a notice of appeal |
| 2. Why is it relevant? | The level, category or business plan it serves | Level 1 immigration work the firm does weekly | The firm plans to apply for Level 2 |
| 3. Where did the need come from? | Annual review, law change, file review or an IAA recommendation | Law change | Business plan |
| 4. How will I achieve it? | The method and provider | Webinar from a training provider, then reading the rules on GOV.UK | Classroom course, then supervised practice |
| 5. What support do I need? | Cost, time, who books it | Two hours; course fee approved by the owner | Two days; cover for appointments |
| 6. Learning objective | What you will be able to do afterwards | Advise on the new requirements without referring up | Draft grounds for a supervisor to review |
| 7. Planned date | A date, not a quarter | 14 November 2026 | 20 January 2027 |
| 8. Date completed | The date, or the reason it did not happen |  |  |
| 9. What did I learn? | Two or three lines in your own words |  |  |
| 10. Evidence held | Certificate, notes, slides, booking email; where it is filed |  |  |
| 11. Did I meet the objective? | Yes, no or partly, and what is still needed |  |  |
| 12. How will I apply it? | The change to casework or process |  |  |

Close the sheet with a review block, completed at least once a year:

- Date of the review meeting and who attended.
- Planned items not completed, with the reason for each.
- Changes in immigration law, practice or regulatory requirements since the last review.
- Whether the adviser wants to widen or change their areas of work.
- Any learning the IAA has recommended, and the date it was completed.
- Items carried into next year’s plan.
- Signatures of the adviser and the person responsible for CPD in the organisation.

Columns 1, 4, 5, 6 and 7 are the IAA plan template’s five questions. Columns 2, 8, 9, 11 and 12 come from its record template, with column 2 adapted from “Why did you do this learning?”. Columns 3 and 10 and the review block are our additions. They follow the booklet’s record-keeping duty, its description of the annual review meeting, and the breach circumstances listed in the section on missing CPD.

## When does the IAA check CPD?

The booklet names three routes for reviewing compliance with Code 4.4: during a compliance audit, as part of a complaint investigation where it is relevant, and by dip sampling. CPD also comes up at two application points: first registration and continued registration, the yearly application to stay registered.

| Point | What happens | Source |
| --- | --- | --- |
| Application for registration | Advisers are asked about their proposed CPD plans for their first year of registration | CPD booklet |
| Continued registration, every year | Organisations indicate their compliance with the CPD scheme; each adviser updates their record with training undertaken in the last year | CPD booklet; IAA registration explained, 8.1 and 9.1 |
| Audit | The audit letter can list CPD records and plans for each authorised adviser; officers may ask advisers about training or CPD on the day | Audit practice note, paragraphs 11 and 12(h) |
| Complaint investigation | Compliance with Code 4.4 is reviewed where it is relevant to the complaint | CPD booklet |
| Dip sampling | The IAA may review CPD compliance by dip sampling; the booklet does not say how samples are chosen | CPD booklet |

The [IAA’s summary of adviser regulations](https://www.gov.uk/government/publications/regulations-that-immigration-advisers-must-follow--2/regulations-that-immigration-advisers-must-follow) says it aims to audit all newly regulated organisations within 12 months of approval and decides when further audits are required. The [IAA practice note on audits](https://assets.publishing.service.gov.uk/media/68d6b710c487360cc70c9e36/Practice_note_on_audits_for_IAA_regulated_organisations_-_September_2025.pdf)(September 2025) tells organisations to have CPD plans and records available for all authorised advisers, “as these will almost certainly be requested to be reviewed on the day”. CPD is one line of the evidence list in our [IAA audit checklist](https://vexralabs.com/insights/iaa-audit-checklist), which sets out the rest of what an audit reviews.

The burden sits with the firm. The booklet says the duty is on the organisation and adviser to demonstrate that they have considered CPD, “and not for the Commissioner to demonstrate that they have not”.

## What happens if CPD records are missing?

The Commissioner may treat the organisation, the individual adviser or both as in breach of Code 4.4. For a minor breach, the booklet says the Commissioner will discuss it with the organisation and is likely to make specific recommendations for future CPD activity.

The booklet says the circumstances in which a breach may be found include where:

1. no evidence exists that an annual programme of planned CPD activity has been produced;
2. planned activity cannot be shown to be relevant to the individual or the business;
3. planned activities have not been undertaken, without a justifiable explanation;
4. the organisation fails to complete recommended learning and development that the Commissioner asked it to do.

The stronger outcomes apply where a failure to plan or complete appropriate CPD has resulted in a failure to deliver fit and competent advice and services. In that case the booklet says the possible sanctions could include:

1. requiring the authorised adviser to undertake specific training or development immediately;
2. requiring the authorised adviser to take a competence assessment;
3. varying the adviser’s registration, which can in turn affect the level and categories in which the organisation is regulated;
4. cancelling the registration of the individual authorised adviser, the organisation or both.

## Where do CPD records sit next to case records?

CPD records are records about advisers, and case records are records about clients, so they usually live in different places. Code 4.4 is one Code among nine Principles, and our [IAA Code of Standards 2024 guide](https://vexralabs.com/insights/iaa-compliance-guide) covers the client-file duties that sit beside it.

Filyst, our case software for immigration firms, has no CPD plan or record feature, and we would rather say so than imply it. What it does record is four-eyes sign-off: a second person approves each case stage, and the approver cannot be the person who did the work. The booklet suggests file reviews as one way to measure whether learning improved performance, and a sign-off history is material for that review. The plan and the record themselves belong in the IAA’s templates or a sheet like the one above. [Software for immigration firms](https://vexralabs.com/immigration-firms) describes what Filyst holds on the case side.

Not legal advice

This guide summarises the IAA’s CPD booklet, Code of Standards 2024, Guidance Notes and practice notes as published on GOV.UK on the date checked. The template is ours and is not an IAA form. Check the IAA’s current documents, or ask the IAA, before relying on it for your registration.

## Frequently asked questions

### Does the IAA require a minimum number of CPD hours?

No. The IAA's Guidance Notes on Code 4.4 say the scheme is not prescriptive as to how much CPD activity advisers undertake. Each organisation decides how much and in what format, as long as it keeps each adviser fit and competent.

### Do advisers send CPD records to the IAA every year?

Not the plans and records themselves. The CPD booklet says organisations indicate their compliance when they apply for continued registration. The IAA's registration guidance adds that each year, at continued registration, advisers update their record with the training they did in the last year. The full plans and records are inspected at a compliance audit, in a relevant complaint investigation and by dip sampling.

### Do self-study and the IAA's training videos count as CPD?

Yes. The booklet treats self-study as informal learning, provided it is relevant to the adviser's work and recorded. The IAA said on 18 June 2026 that its training videos carry no certificate and may be logged as CPD.

### Who is exempt from the IAA CPD scheme?

Three groups: advisers qualified to provide immigration advice in the UK by a Designated Qualifying Regulator or Designated Professional Body, those exempt by Ministerial Order under section 84(4)(d) of the Immigration and Asylum Act 1999, and authorised advisers on maternity leave or long-term illness.

## Sources

1. [IAA, CPD Scheme and Practice Note Booklet (Word document)](https://assets.publishing.service.gov.uk/media/682c573fa4a41a5b3eb00c72/Continuous_Professional_Development__CPD__Practice_Note_2025.docx)
2. [IAA, Continuing Professional Development Scheme (booklet, plan and record templates)](https://www.gov.uk/government/publications/oisc-continuing-professional-development-scheme)
3. [IAA, Code of Standards 2024 (PDF)](https://assets.publishing.service.gov.uk/media/6776b2ef6c34906cc84c9499/IAA_Codes_of_Standards_2024.pdf)
4. [IAA, Code of Standards 2024: Guidance Notes (PDF)](https://assets.publishing.service.gov.uk/media/66a8b9eda3c2a28abb50d95d/Guidance_Notes___Code_of_Standards_2024.pdf)
5. [IAA, Code of standards (publication page with the effective date)](https://www.gov.uk/government/publications/oisc-code-of-standards-commissioners-rules-2012)
6. [IAA, Practice note on audits for IAA regulated organisations, September 2025 (PDF)](https://assets.publishing.service.gov.uk/media/68d6b710c487360cc70c9e36/Practice_note_on_audits_for_IAA_regulated_organisations_-_September_2025.pdf)
7. [IAA, Regulations that immigration advisers must follow](https://www.gov.uk/government/publications/regulations-that-immigration-advisers-must-follow--2/regulations-that-immigration-advisers-must-follow)
8. [IAA, IAA registration explained](https://www.gov.uk/government/publications/iaa-adviser-registration-explained/iaa-adviser-registration-explained)
9. [IAA, IAA launches training video series to support advisers](https://www.gov.uk/government/news/iaa-launches-training-video-series-to-support-advisers)