Before taking the exams, most of what I read online was fairly consistent about the differences between the CFA and FRM programs. The CFA was generally described as broader and more time-consuming, while the FRM was considered narrower but more technical. After completing the CFA, FRM, and CAIA programs, I found those general descriptions mostly accurate. Benchmarks such as roughly 300 hours of study per CFA level were also useful for understanding the commitment beforehand. What was harder to appreciate was what those hours actually felt like. I could be deep into the curriculum and still see how much material remained, while also wondering whether I would remember enough of what I had already studied by exam day.
That experience also changed how I think about the question of which exam is harder. Difficulty is not just about how challenging the questions are on exam day. It also includes the amount of material, the number of exams, the format, and how long you need to maintain the effort.
My conclusion: the FRM is more technical in certain areas, but I found the CFA program harder overall because of its breadth, three-exam structure, and the amount of material candidates have to retain.
In This Post
Pass Rates Tell Only Part of the Story
One way to compare the difficulty of the CFA and FRM exams is to look at historical pass rates. CFA pass rates have changed substantially over time, with some earlier periods showing considerably higher pass rates than candidates have experienced in recent years.
Historical CFA Pass Rates, 1963–2026

The long-term averages help put those fluctuations in perspective. From 1963 through 2026, average pass rates were 41% for Level I, 46% for Level II, and 55% for Level III. Over the most recent five years, Levels I and II remained at 41% and 46%, while Level III fell to 49%.
CFA Long-Term vs. Five-Year Average Pass Rates

By comparison, FRM pass rates have generally been higher on an individual-exam basis, particularly for Part II.
Historical FRM Pass Rates, 2010–2023

Those individual pass rates, however, do not tell the whole story. Candidates must pass three CFA levels compared with two FRM parts. Multiplying the published pass rates provides a simple way to illustrate how those additional exams affect the implied cumulative pass rate. This is not an actual cohort completion rate, since the published figures represent different groups of candidates and exam administrations.
For 2023, for example, the product of the CFA Level I, II, and III pass rates produced an implied cumulative rate of 8.3%, compared with approximately 24% for the two FRM parts. In simple terms, the published pass rates suggest that getting through every required CFA exam was significantly less likely than getting through both FRM parts.
Implied Cumulative CFA vs. FRM Pass Rates

The CFA Curriculum Is Much Larger
Pass rates are ultimately influenced by several factors, including how much material candidates are expected to learn and retain. One way to compare curriculum size is by looking at the number of readings or learning modules, but that can be misleading. FRM Part II, for example, contains 107 readings, more than twice the 45 learning modules in CFA Level II, but those readings are considerably shorter on average.
Approximate 2026 CFA and FRM Curriculum Structure

Note: CFA Level III figures assume the Portfolio Management pathway. Average pages per reading/module are approximate and based on total curriculum pages divided by the number of readings or learning modules.
Looking at total curriculum pages gives a better sense of the overall volume candidates are expected to work through. The 2026 CFA Level I curriculum spans roughly 3,300 pages, depending on format, while Levels II and III each contain several thousand pages. By comparison, FRM Part I is approximately 1,140 pages and Part II around 1,400 or more.
Approximate CFA vs. FRM Curriculum Pages

The Exam Formats Are Also Different
The amount of material is only part of the challenge. The way candidates are tested on that material also varies between the two programs. The CFA program changes as candidates progress, with Level I consisting of standalone multiple-choice questions, Level II moving to vignette-based item sets, and Level III combining item sets with constructed-response questions. CFA multiple-choice questions use three answer choices, while FRM questions use four. Both parts of the FRM are multiple-choice exams. The infographic below summarizes the key format differences between the two programs.
CFA vs. FRM Exam Format Comparison

Try It Yourself: CFA vs. FRM Sample Questions
Below are two sample questions that give a small taste of the style and structure of each exam. They are not enough on their own to judge overall difficulty, but they help illustrate the difference between CFA’s three-choice format and FRM’s four-choice format.
An investor owns gold futures that are approaching expiration. The market is in contango, and the position will be rolled forward while maintaining the same dollar exposure. What will most likely happen to the number of futures contracts held?
Under the Black-Scholes framework, when are the deltas of European calls and puts most sensitive to a change in the price of the underlying asset?
Questions adapted from CFA Institute Level II sample questions and GARP FRM Part I practice materials .
My Verdict: CFA vs. FRM Difficulty
For me, CFA Level III was the hardest single exam. The FRM program felt more technical and specialized in certain areas, but CFA required a greater overall commitment because of its breadth, three-exam structure, and changing formats.
Overall, I would give the CFA program the edge in difficulty. Someone who struggles with quantitative risk concepts could reasonably find the FRM harder, but across the full programs, CFA demanded more from me in both volume and endurance.

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