Public Accounting Licence

When a Public Accounting Licence (PAL) is required

A PAL is required if you practice public accounting as described in section 2 of the Public Accounting Act:

• any assurance engagement (including an audit or review engagement) relating to a financial statement or any part of a financial statement or any statement attached to a financial statement
• any compilation engagement in respect of which it can be reasonably expected that the services will be relied upon or used by a third party and the prescribed wording for the Compilation Engagement Report is not used

• A report is issued in Ontario when it is datelined in Ontario, meaning the jurisdiction indicated on the bottom of the report is in Ontario

• The work is primarily performed in Ontario if the engagement is physically performed in Ontario or if the engagement is performed remotely and the client is in Ontario
• In determining whether the client is in Ontario, the following factors, none of which is individually dispositive, should be considered:
  • Where is the client company formed/incorporated?
  • Where is the client company's head office located?
  • Where is the client company's mind and management located?
  • Where are the client company's books and records located?
  • Where is the client company listed, if applicable?
  • Who is the client company's principal securities regulator, if applicable?
  • Which framework is used for financial reporting?
  • Which assurance standards are being used for the engagement?

The above information is meant to provide a preliminary assessment and not a definitive answer. If you need assistance working through this determination, please contact [email protected]. Users are cautioned that where a scenario is incomplete or changes, the response may vary. Users accept responsibility for conducting their own due diligence and obtaining their own legal counsel in respect of this assessment.

Engaging in the practice of public accounting without holding a valid Ontario PAL is prohibited under the Public Accounting Act, 2004. Please also note that if a PAL is required, membership and firm registration are always required. If a PAL is not required, membership and/or firm registration may still be required. More information can be found here.

Unlawful Practice and Credit for Cooperation

As part of its public protection mandate, CPA Ontario has a duty to investigate and, in appropriate cases, prosecute individuals and firms who are not registered with or licensed by CPA Ontario but nonetheless practice as chartered professional accountants and/or public accountants in Ontario. To encourage full, voluntary and timely self-reporting of potential breaches of the provisions prohibiting unlawful practice, namely section 29 of the Chartered Professional Accountants of Ontario Act, 2017, and sections 13, 14 and 15 of the Public Accounting Act, 2004, (the Acts) and assistance in its investigation of same, CPA Ontario may offer Credit for Cooperation to firms and individuals who may be offside. Early and complete self-reporting of unlawful practice supports identification and remediation of such conduct in the public interest. 

By fully disclosing offending conduct and cooperating with CPA Ontario, firms and individuals may reduce or avoid the penalties ordinarily imposed for such conduct. Examples of cooperation include timely and complete self-reporting; disclosure of relevant documents and information; and taking immediate steps to come into compliance with the applicable legislation, among others.

Whether credit is provided, and the extent of that credit, will vary depending on factors including but not limited to the extent and duration of the conduct, and the extent of any harm to the public.  Where the conduct is particularly serious, CPA Ontario’s duty to protect the public may necessitate prosecution notwithstanding the level of cooperation provided.

Self-Reporting

Credit for Cooperation may be granted to individuals and firms from outside of Canada, as well as to those registered and licensed in other Canadian jurisdictions.

If you believe that you or your firm may have breached the Acts, and you would like to be considered for Credit for Cooperation, you or your legal counsel may contact [email protected].

CPA Ontario encourages you to obtain independent legal advice as part of the self-reporting process.

Eligibility requirements

You can obtain a PAL if you are a member in good standing with CPA Ontario and have met the eligibility requirements (including practice inspection and continuing professional development).

If you wish to engage in the practice of public accounting after obtaining a PAL, you must be employed at a CPA Ontario registered firm or register your own firm with CPA Ontario.

For the full list of eligibility requirements, please review Regulation 17-1.

CPA Ontario students are not eligible to obtain a PAL prior to admission to membership. Learn more about the public accounting path in order to be eligible to apply for a PAL upon admission to membership.

CPA Ontario members who do not have the educational requirements for licensure can complete the Post Designation Public Accounting (PDPA).

Apply for a Public Accounting Licence

If you fulfil the licensing eligibility requirements, you can apply and pay your fee by logging into My Portal, selecting Obligations and Requests ► Applications ► Start New Application ► PAL Application.

The Public Accounting Licensing Board (PALB) reviews your application. You should receive a response within four to six weeks, but timelines depend on having completed all components of the application and volume.

If you are granted a PAL, you will receive a digital certificate by email, along with a letter of approval from the Public Accounting Licensing Board. Your name will be added to CPA Ontario’s public accounting directories.

To maintain your public accounting rights in Ontario, you must renew your PAL annually through My Portal. Licences expire on October 31 each year. You must complete the PAL renewal process by October 1 in order to maintain the licence.

Exemptions for Public Accountants

You are exempt from licensing if you provide public accounting services exclusively in respect of:

• any public authority or any commission, committee or emanation of a public authority, including a Crown corporation
• any bank, loan or trust company
• any transportation company incorporated by an Act of the Parliament of Canada
• any other publicly-owned or publicly-controlled public utility organization

If you practice public accounting without reward, you are still required to provide these services through a registered firm and hold professional liability insurance. You can apply for insurance coverage at no cost if you provide free assurance services to small charitable and not-for-profit organizations with annual gross revenue of $100,000 or less.

Internationally Trained Accountants

Interested in becoming a member of CPA Ontario through a mutual recognition agreement (MRA) or a Reciprocal Membership Agreement (RMA) and obtaining a PAL? Check out our CPA Reciprocity Education and Examination (CPARE) Program.

Please note that the MRA and RMA are for admission to membership only. Members who wish to obtain a PAL must meet additional specific requirements. Please see Regulation 17-1 for more information on licensing eligibility.