CPE 2026: the first year of the new slabs, and who owes the full 40

Summary

From calendar year 2026 ICAI replaced the three-year rolling block with annual age slabs, so a Certificate of Practice (COP) holder under 60 owes 40 CPE hours in 2026, 20 of them structured, by 31 December. A member who qualified in 2025 was exempt only for 2025 and owes the full 40 this year, and a shortfall now comes back next year as twice the missing hours.

The situation

About three months are left in the first year under the new slabs, and the members I hear from fall into two groups. The first group qualified in 2025, took a COP, and remembers being told new members are exempt from CPE. That was true for 2025 and it is not true for 2026. The second group has been in practice for years and still thinks in blocks: a light year is fine, you catch up later. Under an annual requirement there is no later. The year closes on 31 December, and the make-up is double.

Neither group is careless. The circular was issued on 31 December 2025 and reached most people as a headline, "CPE hours now depend on age". The pieces that decide an individual member's number sit in ICAI's FAQ and in the fine print of two reproductions, not in the headline.

The rule

The revised requirement was announced by ICAI's CPE Committee on 31 December 2025 and applies from calendar year 2026. The fullest reproduction of the announcement (TaxGuru, re-read today) gives this table:

Four rules around the table decide which row a given member is in:

• Age is taken for the whole year. A member who attains 60, 70 or 80 at any time during the calendar year is treated as being in that bracket for the whole year (the announcement's own wording). A COP holder who turns 60 in November 2026 owes 30 hours, not 40.
• COP turns on 30 June, not on a pro-rata share. ICAI's CPE FAQ (last updated 22 May 2026) says that a COP obtained on or before 30 June brings the COP-holder requirement for the whole year, and a COP obtained after 30 June brings the non-COP requirement. A surrender works the other way round. Where a COP is both taken and surrendered in the same year, the test is whether it was held for 183 days or more.
• The first-year exemption covers one calendar year. The FAQ exempts a member for the calendar year in which membership is first obtained. The obligation starts on 1 January of the next year.
• Exemptions are claimed, not assumed. Pregnancy, disability of 40% or more, critical illness (decided case by case) and the permanent categories are claimed by self-declaration with documents on the CPE portal. The revised exemption conditions came from the 445th Council meeting. A member who generates a UDIN in a year for which exemption is claimed must still complete at least 10 hours.

If you fall short, the four-level framework applies. For a 2026 shortfall, the windows fall as follows:

Make-up hours are logged on the portal against the current year, on top of that year's own slab.

Where people go wrong

"I am a new member, so I am exempt." You were exempt for the year you joined. If you qualified in May 2025 and took a COP, 2025 was free and 2026 is a full 40-hour year, with 20 structured. This is the most common wrong answer I see, and it hits the members least likely to have a CPE habit yet.

Assuming all 20 structured hours can be done on the Digital Learning Hub. One reproduction of the revised rules (TaxGuru's first write-up) says that at most 4 of an under-60 COP holder's 20 structured hours may be virtual, with the excess treated as unstructured. The fuller reproduction does not carry that cap. Until ICAI's own text settles it, the cap is reported, not settled. It matters because it decides whether a member who did everything online is compliant or 16 structured hours short. Check how the portal has classified your hours before you pay for physical sessions you may not need.

Mandatory topics. The same first write-up requires 2 structured hours on Standards on Auditing and 2 on the Code of Ethics each year for under-60 COP holders. The fuller reproduction does not mention them. Treat this as reported, and do the four hours anyway: they count towards the 20 either way.

Taking a COP in July and budgeting for 40. A COP granted on 15 July 2026 puts you on the non-COP row for 2026: 20 hours of either kind. A COP granted on 20 June puts you on 40. The two dates are five weeks apart and the requirements differ by 20 hours, 20 of them structured.

Waiting for an extension. ICAI extended the 2025 year once, to 31 March 2026, at one-for-one. As at 26 September 2026 nothing similar has been announced for 2026, and I would not plan around one. If you finish short on 31 December, the price is twice the gap in 2027, on top of 2027's own slab.

What to do

1. Work out your row for 2026 from your age at 31 December 2026 and your COP position at 30 June 2026, not from how you felt about CPE under the old block.
2. If you became a member in 2025, treat 2026 as a full year and count your structured hours first. They are the part that cannot be bought in the last week of December.
3. Open your CPE portal record and check how each structured hour has been classified, particularly Digital Learning Hub hours, before booking anything new.
4. Declare any unstructured learning activities on the portal well before year-end rather than in the final days of December.
5. If you carry a 2025 shortfall, add twice that shortfall to your 2026 target and log it against 2026.

The tool

I built a small CPE resolver because every member who asked me "how many do I owe?" needed the same five facts before I could answer: the year, the date of birth, the COP position at 30 June, the hours already logged and any carried shortfall. You enter those. It gives you one sentence ("You owe 40 CPE hours in 2026 and you have logged 22, so 18 to go, with 96 days left"), the structured and flexible split, what is left in each, and, if you are short, which level of the ladder you would land on and on what dates. Hours logged beyond this year's slab are credited against last year's make-up. Where the reported 4-hour virtual limit costs you structured hours, it says so, names both readings and sends you to the portal rather than settling the point. It does not read cpeicai.org, it does not decide whether an exemption will be accepted, and it models nothing before 2026. The portal is still the ledger. Nothing you type leaves your browser.

Open the cpe hours 2026 page

Sources

1. ICAI — FAQs on Continuing Professional Education (last updated 22 May 2026) — https://icai-call-sahayata.icai.org/assets/pdf/CPE-FAQs.pdf
2. TaxGuru — Revised CPE hours requirements for members, calendar year 2026 onwards (reproduces the CPE Committee announcement of 31 December 2025; re-read 26 Sep 2026) — https://taxguru.in/chartered-accountant/revised-cpe-hours-requirements-members-calendar-year-calendar-year-2026-onwards.html
3. TaxGuru — ICAI revamps CPE norms from 2026: hour slabs and penalties (four-level framework; the 4-hour DLH cap and the mandatory SA/Ethics hours) — https://taxguru.in/chartered-accountant/icai-revamps-cpe-norms-2026-hour-slabs-penalties.html
4. TaxGuru — ICAI revises conditions for CPE exemption (445th Council meeting; self-declaration; UDIN 10-hour rule) — https://taxguru.in/chartered-accountant/icai-revises-conditions-cpe-exemption-members.html
5. StudyCafe — revised CPE hours effective 1 January (age cut-off wording) — https://studycafe.in/icai-announces-revised-cpe-hours-requirements-for-members-for-each-calendar-year-effective-jan-1-405151.html
6. CAclubindia — ICAI extends CPE compliance for calendar year 2025 to 31 March 2026 — https://www.caclubindia.com/news/icai-extends-cpe-compliance-deadline-for-calendar-year-2025-to-march-31-2026-26045.asp