PGY 2? Not everyone is exempt
CPD Homes, PGY2 positions and IMGs: who actually needs to do CPD?
There has been understandable confusion about which doctors need to do continuing professional development through a CPD Home.
Most of the confusion relates to doctors who are working in roles described as “PGY2”, “RMO2”, “second-year resident”, or “PGY2-equivalent”. This is particularly common for international medical graduates (IMGs), who may be placed into Australian hospital positions equivalent to a second-year resident because they require a higher level of supervision.
The important point is this: being employed in a PGY2-level job, or practicing under Level 2 supervision, is not the same as being in the accredited PGY2 training program that creates an exemption from CPD Home requirements.
For most IMGs, the answer is straightforward: you need a CPD Home, and you need to complete CPD.
The general rule: most doctors need a CPD Home
The Medical Board of Australia states that, unless exempt, doctors must join an AMC-accredited CPD Home before they start doing CPD each calendar year, log their CPD with that home, complete the required CPD activities, and declare their CPD Home at annual registration renewal.[1]
The standard CPD requirement is 50 hours per calendar year, including:
reviewing performance and measuring outcomes
educational activities
activities relevant to the doctor’s scope of practice
any required culturally safe practice, addressing health inequities, professionalism and ethical practice requirements, often referred to as CAPE requirements.[1]
A CPD Home is not simply a place to store certificates. It is the organisation responsible for supporting, recording, auditing and reporting CPD compliance for its members.[2]
Who does not need to join a CPD Home?
There are some exemptions, but they are narrow.
The key exemption relevant to this article is for:
Interns in accredited intern training programs and PGY2 doctors who are participating in a formal PGY2 training program accredited by a State or Territory postgraduate medical council, or equivalent, that leads to a certificate of completion (the “PGY2 certificate”).[1,2].
That wording matters.
It does not say that every doctor with “PGY2” in their job title is exempt. It does not say that every doctor working under supervision is exempt. It does not say that an IMG working in a second-year resident position is exempt.
The exemption only applies where the doctor is actually participating in the formal, structured, accredited PGY2 program that leads to a PGY2 certificate of completion.
The source of the confusion: “PGY2 certificate” versus “AMC Certificate”
A major cause of misunderstanding is the word “certificate”.
There are two different concepts that can sound similar:
The PGY2 certificate of completion
This relates to the National Framework for Prevocational Medical Training. It is issued when a doctor successfully completes an accredited structured PGY2 program.The AMC Certificate for IMGs
This is issued to international medical graduates who successfully complete the Australian Medical Council assessment process for the Standard Pathway to registration.[3]
These are not the same thing.
An IMG may be working towards an AMC Certificate. They may be working in a supervised position. They may be employed in a job that looks similar to a PGY2 resident role. But that does not mean they are in the accredited PGY2 program that creates an exemption from CPD.
The Medical Board has specifically clarified that working towards an AMC Certificate is different from working in an accredited, structured PGY2 position. The Board has also stated that IMGs working in hospital positions equivalent to PGY2 doctors do still need to complete CPD.[4]
Confusingly, the AMC issues both of these certificates, leading to significant confusion.
IMG doctors with limited or provisional registration
For IMGs with limited or provisional registration who are working towards general registration, the Medical Board’s position is clear:
You are not exempt from CPD requirements. You must have a CPD Home and complete all CPD requirements. CPD is required even when you are working under supervision in a PGY2-level position.[1]
This includes IMGs on the Competent Authority Pathway who hold provisional registration and are completing supervised practice. The Board states that doctors on this pathway need a CPD Home and must do 50 hours of CPD each calendar year.[5]
This also includes IMGs on the Standard Pathway who hold limited or provisional registration while working towards general registration, unless a very specific exemption applies.
It is also important to note that your CPD requirements are based on a CALENDAR year (1st Jan to 31st Dec) regardless of when you are registered or begin work. They are NOT related to your registration cycle.
Additionally, you may be entitled to a pro-rata reduction in your hours if you were registered in Australia for less than 6 months of the year. This is based on your registration date (not your job commencement date or the day you enter Australia).
Supervision level does not decide CPD requirements
Some doctors have been told they require “supervision level 2” as a condition of registration. That may be important for their registration and employment arrangements, but it does not determine whether they need a CPD Home.
A supervision level is not the same as being enrolled in the accredited PGY2 training program.
Similarly, being employed in a job equivalent to PGY2 is not enough. The question is not, “What level is my job?” The question is:
Am I participating in the formal, structured, accredited PGY2 program that leads to a PGY2 certificate of completion?
All such programs are run by accredited supervisors - contact yours for clarification.
If the answer is no, you need a CPD Home unless another exemption applies.
Australian-trained doctors: PGY2 is not the same as internship
Australian and New Zealand medical graduates usually complete one year of accredited internship, or PGY1, while holding provisional registration. After satisfactory completion of PGY1, they become eligible for general registration.[6]
The newer PGY2 certificate process sits within the National Framework for Prevocational Medical Training, but it is not a second year of internship. PGY2 requirements are separate from the PGY1 requirements for general registration.[7]
This is important because the PGY2 certificate is not mandatory for general registration. Australian-trained doctors generally become general registration holders after successfully completing PGY1.
If they then participate in the accredited PGY2 program that leads to a certificate of completion, they are deemed to have met the CPD standard through that program. If they are not participating in that program, they need to meet the Board’s CPD registration standard, including enrolling with a CPD Home.[1]
Practical examples
Example 1: Australian-trained intern in an accredited internship
You do not need to join a CPD Home. Your CPD is taken care of through your intern training program.[1]
Example 2: Australian-trained PGY2 in the formal accredited PGY2 program
You do not need to join a CPD Home. You are deemed to meet the CPD standard through your PGY2 position and associated education, provided the program is accredited and leads to a certificate of completion.[1]
Note : you will need to upload a copy of your PGY2 Certificate when you renew your registration the following year as proof you were exempt - failing to do this may result in AHPRA taking action against you.
Example 3: Australian-trained doctor in a PGY2-level job but not in the formal accredited PGY2 program
You need a CPD Home and you need to complete CPD.[1]
Example 4: IMG with provisional registration, working under supervision in a PGY2-level hospital job
You need a CPD Home and you need to complete CPD. The fact that the job is PGY2-level does not create an exemption.[1,4]
Example 5: IMG working towards an AMC Certificate
You need a CPD Home and you need to complete CPD. Working towards an AMC Certificate is not the same as completing the accredited PGY2 program that leads to a PGY2 certificate of completion.[3,4]
What should you do if you are unsure?
If you are an IMG, or if you are in a role described as PGY2, RMO2, second-year resident or PGY2-equivalent, do not rely on the job title alone.
Ask your hospital Director of Training, Medical Education Unit, or equivalent medical education office:
“Am I participating in the formal, structured, accredited PGY2 program that leads to a PGY2 certificate of completion?”
If the answer is yes, ask them to confirm that the program is accredited by the relevant State or Territory postgraduate medical council, or equivalent.
If the answer is no, you should assume you need a CPD Home unless another specific exemption applies.
The safe approach
The risk for doctors is that they may incorrectly assume they are exempt, complete no CPD through a CPD Home, and then be non-compliant at registration renewal or audit.
For IMGs, the Medical Board has been explicit: IMGs need a CPD Home and need to complete 50 hours of CPD each year, even if they are working in a hospital position equivalent to PGY2.[4]
The good news is that many of the activities IMGs already do as part of supervised practice can often be recorded as CPD. Learning sessions, orientation activities, workplace assessments, supervisor meetings, feedback, performance review, case discussions, audit activity and preparation for AMC-related requirements may all contribute, provided they meet the CPD Home’s requirements and are recorded properly.[4]
The bottom line
If you are an IMG with limited or provisional registration, you almost certainly need a CPD Home.
The PGY2 exemption only applies to doctors who are genuinely participating in a formal, structured, accredited PGY2 program that leads to a PGY2 certificate of completion.
When in doubt, confirm your status with your Director of Training — and do it early. It is much easier to record CPD as you go than to discover at the end of the year that you were required to have a CPD Home all along.
References
Medical Board of Australia. What do I need to do? Continuing professional development. (Medical Board of Australia)
Medical Board of Australia. About CPD homes. (Medical Board of Australia)
Medical Board of Australia. Australian Medical Council certificate holders. (Medical Board of Australia)
Medical Board of Australia. March 2026 newsletter: CPD requirements for IMGs. (Medical Board of Australia)
Medical Board of Australia. Competent Authority pathway: CPD requirements. (Medical Board of Australia)
Medical Board of Australia. Interns: Australian and New Zealand medical graduates and PGY1 training. (Medical Board of Australia)
Postgraduate Medical Council of Western Australia. PGY2 requirements from 2025 onward. (pmcwa.org.au)
Medical Board of Australia. Supervised practice for international medical graduates guidelines (https://www.medicalboard.gov.au/Codes-Guidelines-Policies/Supervised-practice-guidelines)