Guide 08 · Permit holders
APEGA CPD for permit holders and Responsible Members
Independent guide. PaceTracker is not affiliated with APEGA. Requirements can change: always confirm against APEGA’s official documents, linked at the end.
The short answer. Under APEGA’s CPD practice standard, CPD is the obligation of each licensed professional: the learning modules, the PACE plan, the activities and the declaration are theirs (s. 1.1 and 3.1). The standard does not give a permit holder or a Responsible Member a CPD obligation for the people they employ. What APEGA asks of a permit holder sits elsewhere: the Professional Practice Management Plan practice standard asks for a process to support continued competence, and the PACE guideline describes how an employer can support the CPD of its licensed professionals.
According to APEGA's September 2026 notice, the revised CPD standard is enforced at each professional's renewal on or after November 1, 2026, and the due date follows each person's renewal month: across a team, deadlines arrive every month.
01 Who carries the CPD obligation
The CPD practice standard applies to practising licensed professionals (s. 1.1). Each of them completes the learning modules assigned in myAPEGA, creates and follows a PACE plan, completes at least two CPD activities with a written explanation and evidence for each, and declares in myAPEGA by their CPD due date (s. 3.1). The plan, the evidence and the declaration belong to each professional; the standard does not ask the employer to submit anything for them. The year-by-year detail is in our guide to the annual CPD requirements, and each professional’s dates follow their renewal month, listed in our deadlines by renewal month.
02 The Responsible Member’s own requirements
A Responsible Member is a licensed professional, so the CPD standard applies to their own record exactly as it does to everyone else’s. On top of it, the General Regulation requires a Responsible Member to complete the Permit to Practice seminar every five years (s. 48.1). The CPD standard treats the seminar as a separate obligation, not as part of CPD (s. 3.1).
03 What the PACE guideline expects of permit holders
APEGA’s PACE practice guideline describes how a permit holder can support the CPD of the licensed professionals it employs: encouraging it, consulting with them on their activities, offering learning opportunities, holding periodic performance reviews, providing financial support, and allowing time (s. 2.2). A practice guideline sets out recommended practice rather than requirements.
In practice, most of these happen in conversations the firm already has: a periodic performance review is a natural moment to look at the skills in the professional’s PACE plan, and a training budget or time allowance is easier to plan when the activities the professional intends to complete are known early in the period.
04 The PPMP: continued competence and roles
APEGA's Professional Practice Management Plan practice standard asks permit holders for a process to support the continued competence of the licensed professionals they employ (s. 4.7.2, apega.ca). Each professional's PACE plan remains their own record.
The same standard asks the permit holder to keep a record of the people in its practice: for each, their name, APEGA ID where applicable, position, designation, area of practice, practice status and supervisors, and for each Responsible Member also the status and date of their last Permit to Practice seminar (s. 4.6.3). The process for continued competence is the firm’s own: it describes how the firm supports its professionals, while each professional’s CPD record and declaration stay with the professional.
05 Reviewing a PACE plan
APEGA's PACE guideline recommends, without requiring it, that a licensed professional review their PACE plan with a Responsible Member, supervisor, peer or mentor, and states the reviewer is not expected to confirm completion of activities (apega.ca).
The guideline recommends documenting that the review took place and what came out of it (s. 3.6). A Responsible Member is one of the people who can take this role, and a firm may find it a useful moment of its continued competence process. The review is input on the plan, not a sign-off on the record: APEGA does not approve PACE plans, and a review does not change what the professional declares.
06 Who can ask for the records
The Practice Review Board can request a licensed professional’s PACE plans, for the current year and for past years, and the records that support them (s. 3.2.1). The request concerns the professional’s own record. That is the practical reason the record has to stay with the professional, readable and complete, when they change employer: the plans from years spent at a previous firm can still be requested. How to keep a record ready for a request is the subject of our review readiness guide.
07 How a firm can support this with PaceTracker
A permit holder can open an organization in PaceTracker and cover seats for the licensed professionals it employs. Each professional keeps their own account, with their own renewal date, PACE plan, activities and evidence, and the record stays theirs after they leave the firm. When they join, each professional chooses what the organization can see: Not shared, Status, Summary or Full record.
An organization admin sees at most the Status level. A Responsible Member can see more only when the professional chooses Summary or Full record, and can record that they reviewed a signed plan; the professional decides whether that review appears in their record. The Responsible Member can export a PDF for the permit holder’s files. It shows at most the Status level for each professional who shares, and nothing for those who do not, with the self-check marked Met / Not met · informational. It is not a compliance verdict, and each export is recorded in the organization’s access log.
The competence self-evaluation (section 3 of the PACE plan), written explanations and evidence files are never shared at any level.
Sharing is chosen by each professional, per organization, and can be changed or turned off at any time. Every view of a shared record is logged and visible to the professional.
At any level the organization can ask PaceTracker to send a date reminder; it never contains CPD data.
None of this replaces the firm’s PPMP or the professional’s declaration in myAPEGA. It gives the firm a view, chosen by each professional, of where the team stands across renewal months, and gives each professional a record they keep. The details are on PaceTracker for teams.
· Quick answers
Does a permit holder have CPD obligations under APEGA’s CPD standard?
No. The CPD practice standard places CPD on each licensed professional (s. 1.1 and 3.1). The permit holder’s duty comes from the PPMP practice standard, which asks for a process to support the continued competence of the licensed professionals it employs (s. 4.7.2).
Does a Responsible Member have to complete CPD?
Yes, their own, like any licensed professional. The General Regulation also requires the Permit to Practice seminar every five years (s. 48.1), which the CPD standard treats as separate from CPD.
What does APEGA expect an employer to do about its engineers’ CPD?
The PACE practice guideline describes employer support: encouragement, consultation on activities, learning opportunities, periodic performance reviews, financial support and time (s. 2.2). It is a guideline, so it sets out recommended practice.
Can a Responsible Member review an engineer’s PACE plan?
Yes. The PACE guideline recommends, without requiring it, a review of the plan with a Responsible Member, supervisor, peer or mentor, and recommends documenting it (s. 3.6). The reviewer is not expected to confirm completion of activities.
Who can request an engineer’s CPD records?
The Practice Review Board can request PACE plans for the current and past years and their supporting records (CPD practice standard s. 3.2.1). The request concerns the professional’s own record, including years spent with a previous employer.
Does the firm submit anything to APEGA for its engineers’ CPD?
Not under the CPD standard. Each professional completes the modules and the declaration in myAPEGA. The firm’s continued competence process belongs in its PPMP.
Support your team’s CPD, with records they keep
Each professional keeps their own plan, activities and evidence, chooses what the firm can see, and every view is logged and visible to them. Team seats are free until paid subscriptions start, like individual accounts. Records stored in Canada (Montréal).
See PaceTracker for teamsMinimum 10 seats · Billing agreed in writing