Dabbling in Public Practice without a Licence: It Can Cost You
From CPABC’s Ethics Department
S
ince CPABC became a combined entity in 2015, the ethics department has dealt with a
broad and diverse range of issues, inquiries, and complaints from the public and from
members of the profession. And even though these are still early days, some trends are
emerging. One issue that has cropped up several times is that of CPAs dabbling in public practice
without being licensed to do so. The purpose of this article, therefore, is to reiterate the licensing
requirements and provide additional guidance.
“Public Practice” is a broad term
CPABC Bylaw 100 defines public practice as “…offering to provide public accounting or other
regulated services to the public.” This is a broad definition that includes assurance and compilation
engagements, as well as other regulated services such as summarization, advice, analysis, and
counsel. Also included are taxation-related and statutory filing services, with examples of the
latter including GST, PST, and payroll withholding services. For a complete list of “other regulated
services,” see the Bylaw definitions (under Regulatory in the Members section of the bccpa.ca
website).
If you use the full wording “Chartered Professional Accountant” as either part of your firm
name or as a descriptor of your business services, you are deemed to be carrying on the practice
of public accounting as per Rule 402.1 of the CPABC Code of Professional Conduct, and this
means you require licensing. And even if you do not use the words “Chartered Professional
Accountant” to describe your services, what matters most are the services you offer or actually
provide. You cannot take off your “CPA hat” as a means of avoiding licensing requirements.
Reminder re: Ethics CPD Requirement
Every member must complete a minimum of 120 qualifying hours of
continuing professional development (CPD) during each rolling threecalendar-year period, including at least 60 verifiable qualifying hours.
Among these 60 verifiable qualifying hours, at least four must be
business ethics hours.
This ethics requirement has been in place for CPA, CGAs* for some
time and will continue to be applied on a three-year rolling basis. It is a
new requirement for CPA, CAs and CPA, CMAs, however, and is effective
for the 2015-2017 rolling cycle. CPA, CAs and CPA, CMAs must complete
four hours of business ethics no later than December 31, 2017.
Ethics CPD is learning that specifically addresses business ethics
matters that are relevant and appropriate to the member. For guidance
on the ethics CPD requirement, please refer to our website at
bccpa.ca/cpd-ethics-requirement.
*New CPA, CGA graduates are required to complete a specific seven-hour rules
and standards course as a condition of membership before December 31 of
the first full calendar year of membership. This seven-hour course may count
towards the business ethics requirement for their first three-year rolling cycle.
32 CPABC in Focus • July/August 2016
Some of the cases of unauthorized practice
we’ve dealt with thus far started when CPAs
found themselves between jobs, or in need
of extra work. Wanting to stay productive
and earn some extra income, they offered
their services to a small number of people,
sometimes just starting with family and
friends. Over time, that commitment can
grow; for example, by the time we became
involved, one unlicensed individual had
nearly 100 clients and their work had
evolved into a full-blown business practice,
with an office location, a community profile,
and advertising in local newspapers and the
telephone directory.
Ultimately, whether you’re providing public
practice services for one client or 100 clients,
licensing is required. The only exception to
this rule is discussed in the next section.
Pro-bono work and “CFO-for-hire”
services als