The NMC CPD Audit: What They Actually Check

Most CPD audits close cleanly. The audit isn’t looking for trouble. It’s verifying that the claimed CPD actually happened. A well-organised registrant with reasonable evidence passes audit in three to four weeks with no follow-up beyond providing requested certificates.

This chapter is the realistic picture of what audit involves and what trips submissions up.

How audit selection works

The NMC audits around 2.5% of revalidation submissions. Roughly 1 in 40 nurses.

Selection has two components:

Random. A baseline percentage of submissions are picked at random regardless of any other factor.

Risk-based. Patterns that increase audit likelihood:

• Late submission (close to the deadline rather than the early end of the window).
• All five reflective accounts dated within a fortnight of submission.
• All CPD concentrated in the final months.
• Confirmer from outside the expected pattern (someone the NMC doesn’t recognise as a senior registrant).
• Recent fitness-to-practise activity.

You can’t reverse-engineer audit avoidance, and trying to is the wrong frame. The way to make audit a non-event is to have the evidence ready.

What the auditor asks for

A typical CPD audit letter asks for:

• Your CPD log in the format you submitted it.
• Certificates or attendance evidence for a sample of activities (not always all 35 hours).
• Brief reflections on a sample of activities (typically the longer ones).
• Evidence that the activities were relevant to your scope of practice.

The auditor doesn’t expect a perfect file for every CPD hour. They expect plausibility, evidence for the major activities, and a clear sense of why the learning relates to your role.

What’s checked

Four checks the audit runs:

1. Total hours. Do the entries add up to at least 35? Are at least 20 of them flagged as participatory?

2. Evidence. For the activities sampled, can the registrant produce a certificate, attendance confirmation, or structured record?

3. Relevance. Do the activities relate to the registrant’s scope of practice? A community mental health nurse claiming tropical medicine CPD would trigger a query.

4. Distribution. Is the CPD reasonably distributed across the three years, or concentrated suspiciously?

A submission that passes all four closes with “no further action required.”

What fails

Missing evidence. The most common single failure. A CPD hour claimed but no certificate or note. Sometimes the activity happened but wasn’t recorded; sometimes the activity was claimed loosely without happening at all. Either way, no evidence means the hour can’t be verified.

Concentration anomalies. All 35 hours dated within the final two months. All five reflective accounts dated within a week. These don’t fail automatically but they prompt deeper review, which usually surfaces other issues.

Relevance failures. CPD that doesn’t connect to the registrant’s scope. Half a day of cardiology CPD claimed by a registrant working exclusively in mental health, without any reason cardiology would apply to their work.

Date inconsistencies. A certificate dated 2024 claimed against a cycle ending in 2023. A study day listed as 6 hours but the agenda shows 4 hours of content.

Participatory misclassification. E-learning modules claimed as participatory. The audit usually catches this immediately and asks for clarification on how the activity involved other professionals.

What happens after a failure

A failed audit doesn’t immediately reject the submission. The usual sequence:

1. Initial review identifies an issue.
2. Auditor sends a follow-up asking for the missing evidence or clarification.
3. You have a further period (often 28 days) to respond.
4. If the issue is resolved, the audit closes.
5. If it isn’t, the submission may be rejected or referred for further consideration.

Most issues resolve at step 4. The registrant provides the evidence they had but didn’t include, or accepts that an entry should be removed and the total adjusted, and the submission completes.

Outright rejection is rare. When it happens it’s usually for fundamental issues: fabricated CPD entries, evidence of dishonesty, or unwillingness to engage with the audit process.

How to be audit-ready

The simple discipline: as each CPD activity happens, save the evidence in a folder labelled “Revalidation [year].” Annual or quarterly review of the folder.

For each activity:

• Date.
• Title.
• Duration (count only learning time, not breaks).
• Source or provider.
• Participatory or individual.
• Brief reflection (one or two sentences on what you learned).
• Certificate, attendance confirmation, or structured note attached.

If the folder has 35 hours of evidence by the time you submit, the audit (if it comes) is a non-event.

The “I’m being audited” anxiety

Receiving an audit notice usually produces a worry spike. The realistic perspective:

• The audit isn’t about fault-finding. It’s a verification check.
• The majority of audits close with no further action.
• You have 28 days to respond. That’s enough time to assemble evidence.
• Your union can help if you’re uncertain about how to respond.

The audit notice arrives by email. Read it carefully, note what’s being asked for, gather the evidence, send it within 28 days. The process usually closes in 4 to 8 weeks total.

The next chapter covers how to record CPD properly in a portfolio: the format that survives the audit cleanly.