"Values" statements



PLA and the Chartered Accountants of Ontario
Balancing commitments to fair access with maintaining standards that protect the public

Tom Warner
Registrar, Institute of Chartered Accountants of Ontario


The Institute of Chartered Accountants of Ontario is one of the oldest, and largest professional regulatory bodies in Ontario. We currently have over 27,000 members and over 3,000 students. There is a significant international component to our membership. Over 1,500 of our members are working in 70 countries.

The Institute has long accepted that regulatory bodies have a responsibility to the public to ensure that the competency of applicants is assessed fairly and consistently, that the standard to be met is transparent, clearly communicated and measurable, and that no more is required of an individual with education and training from outside Canada than is required of a person who has qualified in this country. And we believe that we have put the acceptance of those principles into practice over many years now, through the access processes that we have had in place. In fact, 1,492 of our current members originally obtained their professional accounting designations in other countries and then obtained the CA qualification in Ontario.

Professional Self-Regulation:

It is vital that the discussion of PLAR as it relates to access to professional qualification proceed from an understanding of the self-regulatory responsibility that has been given to occupational regulatory bodies.

There has been a long tradition of professional self-regulation in Canada based on public accountability and protection of the public through the maintenance of high professional standards. It has generally served the people of Canada well. That is not to say, however, that there is no room for change or improvement. But, the simple fact of the matter is that the knowledge and expertise necessary to assess competence to practice a profession reside with the members of that profession. The establishment of a role for government that would weaken this fundamental principle must be avoided. Government or other individuals or agencies are not in a position to define for any particular profession what constitutes competence to practice. In the case of chartered accountants, like most other professions, provincial legislation delegates to the professional body the authority to educate, train, qualify and regulate the members of the profession. In our case, the Chartered Accountants Act, 1956, states the objects of the Institute as being:

  • To promote and increase the knowledge, skill and proficiency of its members and students; 
  • To regulate the discipline and professional conduct of its members and students; and 
  • To promote and protect the welfare and interest of the Institute and the accounting profession.
The Act confers on the Institute's governing council the authority to pass bylaws and regulations to:

Prescribe standards and tests of competency, fitness and moral character for the registration of CA students and for membership in the Institute; Provide for establishment and maintenance of classes, lectures, courses of study, systems of training, periods of service and examinations; Provide for the exercise of disciplinary authority over members and students; and Provide for rules of professional conduct.

International Nature of Accounting:

The international characteristic of accounting has long been evident by the movement of individuals from country-to-country to meet the business needs of their firms. Reflecting the evolution of a global economy, international accounting firms have existed for decades. As a result, reciprocity has existed for many years between accounting bodies in various countries. As we all know, governments are now responding to the rapid globalization of business by signing agreements to open borders and facilitate the movement of professionals. Added to this is the increasing expectation of the public that responsible professional bodies will ensure that they have processes that provide professionals from other countries with fair and reasonable opportunities to pursue their chosen careers. I believe that the structures and processes put in place by the accounting profession in Canada and internationally have put the CA profession on an excellent footing for responding to these developments. 


One of the particular challenges faced by the Institute in matters related not only to PLAR and reciprocity with accounting bodies in other countries, but to public perceptions generally, is that, in Canada, not all accountants are the same. In fact, the term "accountant" is generic. It might be used to describe a bookkeeper, a bank clerk, an accounts receivable clerk, the controller of a business, and to a chartered accountant. The name "accountant" can apply to those who never finished high school, to business college, community college or university graduates, or to those who are chartered accountants or members of other accounting professions in Canada. The term "accounting" is used to include everything from basic bookkeeping to preparing financial reports for a wide range of users-management, creditors, investors, government agencies and others.

It is only when a person wants to use a particular accounting designation after his or her name, such as "chartered accountant", that one must be a member in good standing of a professional body. There are also two other major accounting designations in Canada-the Certified Management Accountant (CMA) and the Certified General Accountant (CGA). Each has its own professional bodies, and qualification programs and requirements that are different from those of the CA-qualification program. Accordingly, someone coming to Canada with the intention of being an "accountant" here will have to meet the particular requirements of the respective accounting body if he or she wants to use that body's professional designation.

The licensing requirements for public accountancy vary from province-to-province. Under the Public Accountancy Act, the Institute is the sole qualifying body for access to a public accountants licence in Ontario. Members of other accounting bodies also have the ability to be licensed in several provinces. In one province, public accounting is not a regulated service and anyone can provide such services whether or not they are a member of one of the professional accounting bodies.


History of the Institutes Involvement:

We believe that the CA profession has taken seriously our professed commitment to ensure fair, merit-based access to CA qualification by foreign-trained accountants. This has been demonstrated by a number of initiatives over many years. In 1989, for example, we responded positively when the Ontario government released the recommendations of the Access to Professions and Trades Task Force. The Task Force had been established to investigate whether there were systematic barriers that prevented individuals with education and experience acquired in other countries from entering into or practicing their chosen profession or trade. Some of the task force's recommendations were already encompassed in Institute admission processes:

  • We had a prior learning assessment system both for professional accounting programs in other countries and for evaluating degrees and courses completed at universities outside Canada; 
  • We did not have an English language proficiency test requirement; 
  • We had a hearing process with an appeal provision for consideration of applications received from members of accounting bodies outside Canada with which the Institute had reciprocity.
Coincident with the release of the Task Force recommendations, we completed a review of the requirements to be completed by members of accounting bodies in other countries with which we did not have reciprocity. This review resulted in the granting of exemptions from certain of our program requirements and the introduction of challenge examination provisions. Challenge examinations were cited by the Task Force as acceptable means of providing access to entrance into a professional qualification program by individuals trained and educated outside Canada. We also extended our hearing and appeal processes to such applicants. I'll speak more about that later.

We did not support some aspects of the Task Force's recommendations, including the one that suggested that the prior learning assessment function should be conducted by a government agency with only an advisory role to be played by the professional bodies. We maintained then, and do so now, that such an approach would be an encroachment on the legislative rights and responsibilities of professional self-regulation.

A little over a year ago, we agreed to participate in a pilot project launched by the Ministry to develop an occupational fact sheet on access to chartered accountancy qualification. It was one of the first of a number of fact sheets on different professions that have been developed because many foreign-trained individuals and regulatory bodies have frequently reported that immigrants arrive in Ontario without fully understanding the registration requirements or process they must complete in order to pursue their occupation here.

The Institute is also participating in a research project funded by the Ministry and carried out by the Centre for Applied Social Research (CASR), at the Faculty of Social Work, University of Toronto. It is studying the experiences of newcomers to Canada in attempting to access professions and trades in which they have trained in other countries. It is anticipated that a roster of individuals will be created from which about 400 will be randomly selected for telephone interviews. The objective is to identify issues and needs that could be addressed to better assist individuals who are planning to immigrate to Canada.

The Institute is also working in partnership with Skills for Change, a Toronto agency that assists new arrivals to Canada in becoming settled and finding employment. We are participating in a mentoring program that matches CA mentors with accountants having education or training received in other countries. And we will be sponsoring and participating in a soon-to-be launched program offering information sessions to give foreign-trained accountants information on the accounting profession so that they are better able to plan their future


The access principles were based on two overriding general principles:

  • ONE: occupational regulatory bodies should retain the right to ensure the competency of their members through registration requirements which protect the public's health, safety, economic security and general welfare.

  • TWO: everyone, including individuals educated or trained outside of Canada, should have an equal opportunity to seek registration in the profession or trade for which they have been educated and trained.
Six specific principles were then set out, as follows:
  • Access to information about registration requirements - full and clear information on the registration standards and requirements should be available to prospective applicants.

  • Assessment of qualifications - occupational regulatory bodies have a responsibility to assess applicants' skills fairly, consistently and on merit so all qualified practitioners, including those trained outside Canada, have an opportunity to get registered in the profession or trade in which they have been educated and trained.

  • In particular:
    • Standards and requirements should be transparent and based on knowledge and skills that are needed to practice the occupation safely and competently and should not go beyond such level; 
    • Evaluation procedures should be designed to fairly and accurately assess and recognize knowledge and skills, including academic and experiential learning; 
    • Individuals should be able to demonstrate and get recognition for competencies acquired not only through formal education but also through workplace and other relevant learning experiences; 
    • Assessment processes should be accessible and not impose unreasonable financial burden on applicants; 
    • Full and easily understandable information on the steps required to obtain the necessary knowledge and skills should be provided to applicants who do not meet the requirements.
  • Licensing and registration requirements - Examinations or other assessment tools should be based on criteria relevant to performing adequately in the profession or trade, and should be designed to ensure they are valid, reliable and fair.
    • Examinations should be designed to measure the specific skills needed to practice the occupation safely and competently; there should be both specific indication of the competencies that are to be assessed and demonstration that such are needed to adequately perform the occupation; 
    • Testing experts should review the examinations to ensure they are valid and reliable measurement of the required competencies, and have no unintended hidden barriers which act as impediments to the fair assessment of applicants; 
    • The language and format of the examinations should be accessible, fair and culturally sensitive; language should not be used that is more complex than the language required to practice the profession; 
    • The same registration exams should be required of all candidates, wherever they have been trained. An exception might be made where a convincing case is established that the particular equivalency cannot be readily assessed by means other than an additional examination for foreign-trained candidates. In this case, it would be necessary to demonstrate that it could be inappropriate to impose such an additional exam on domestically trained candidates.
  • Language training - language tests or assessments should be based on criteria relevant to performing adequately in the profession or trade and should be designed to ensure they are valid, reliable and fair. 
    • Bridge Training/Upgrading-individuals should have access to bridge training to allow them to obtain additional training or experience needed to meet Ontario registration requirements. 
    • There should be access to bridge training that allows applicants to build on the skills and knowledge they already possess, such access to be subject to occupational demand and financial feasibility. 
    • Where needed, and subject to occupational demand and financial feasibility, access to bridge training should include an orientation to standards, procedures, technical terminology, and occupation specific language skills needed to practice in the Canadian environment; 
    • Occupational regulatory bodies, colleges and universities should work together in a co-ordinated fashion to explore how to accommodate such applicants within a flexible educational system that ensures prior learning is given recognition and credit; 
    • Information on available opportunities for upgrading should be provided to applicants.
  • The Right to Appeal - applicants must be given clear information on the grounds for refusing registration and have the right of appeal.
    • Written reasons for denial of an application should be provided, including a full and clear explanation of the rationale for how the individual's qualifications have been assessed; 
    • There should be a right of appeal of negative decisions, and such appeal should be heard by persons not involved in the original decision; 
    • Full information on the appeal process should be made available and accessible.

The International Qualifications Appraisal Board (IQAB) is an independent body comprised of representatives of the provincial CA institutes. Since the late 1960's, IQAB has assessed the designations of accounting bodies outside Canada on behalf of, and at the request of, the provincial institutes. It makes recommendations, through the Canadian Institute, on the status to be accorded to members of foreign accounting bodies by the provincial institutes. IQAB's findings and recommendations are not binding on the provincial institutes but ordinarily are accepted and implemented by them.

The purpose of these reviews is to determine whether the education, examination and experience requirements of an accounting body outside Canada are substantially the same as those of the provincial institutes in this country. If IQAB determines that this is the case, it recommends to the provincial institutes that the members of any such body who seek CA qualification in Canada by exempted from writing the Uniform Final Examination (the national qualifying examination). Reciprocity is then ordinarily granted to members of these "designated accounting bodies" if they also grant similar recognition to Canadian CA's.

In other cases, IQAB recommends that reciprocity should not be granted to members of accounting bodies because of substantial differences between the content, knowledge levels or other requirements of their qualification programs and those of the CA program in Canada. These are called "non-designated" accounting bodies, as are bodies outside Canada in respect of which IQAB has not completed an assessment.

Re-reviews are undertaken approximately every five years. In the case of a re-review, IQAB will assess the nature and impact of any process changes implemented since the previous assessment was completed.

For the purpose of determining the degree of equivalency of a foreign accounting body's qualification requirements and processes, IQAB assesses the other body's requirements as a whole rather than assessing the extent to which each component of its program equates to the respective Canadian component. Whenever feasible, IQAB will utilize other external sources in the conduct of its assessments. These other sources could include, but are not limited to, discussions with persons who have acquired business experience both in Canada and the respective country; and other available data on the cultural, business and economic environment in which accountants work in their respective country.

The specific assessment criteria used by IQAB are: 

  • Cultural, business and economic environment; 
  • Education entrance requirements for the body; 
  • Method and scope of the professional examination(s); and 
  • The practical experience requirement.
We believe that as a result of the initiatives taken over several years we have an excellent system in place to ensure fair and appropriate access to our profession by individuals who have received education and training outside Canada. At the initial hearing before the applications committee and again at the appeal committee level, the applicant has the right to be represented by legal counsel, to have anyone of his or her choosing attend to speak in support of the application, to provide any documentation or make any submissions the applicant deems appropriate and to answer questions from the committee members. 


There is also another dimension that is important it is not often addressed-the resources, human and financial, that are required to fulfil the responsibility of ensuring fair, merit-based access. Staff are needed to develop and administer the processes, to produce information materials, review documentation and respond to inquiries. As our processes involve interviews or hearings at which applicants attend, members of the profession need to be enlisted as decision-makers, as volunteers who take time away from their practices or employment. Staff support to provide written reasons and legal advice to ensure fulfillment of the requirements of law and due process are also required.


At this point, I will provide a brief overview of the CA program requirements to serve as an introduction to specific examples of how PLAR has assisted foreign-trained accountants in becoming CA'S in Ontario.

Each provincial institute's CA-qualification program consists of three basic components:

  • Pre-professional education; 
  • A professional program of prescribed courses and examinations including the National Uniform Final Examination; and 
  • A prescribed amount and nature of public accounting experience.
There are three routes by which membership in a provincial institute may be gained:
  • By registering as a student and completing the CA qualification program; 
  • By affiliation from another provincial institute, in which case no other requirements, such as re-examination, are prescribed; 
  • By reciprocity from a designated accounting body outside Canada, after successful, writing the CA Reciprocity Examination.
Individuals who have received university degrees from outside Canada but who do not have an accounting designation may register as students in the CA program. In Ontario, we conduct individual assessments of the courses taken within their degree programs to compare the content with the requirements of our syllabus, in the same way that we assess the content of courses taken for degree programs at Canadian universities. This makes graduates of universities from outside Canada eligible to receive exemption from most of the 17 prescribed courses in accounting and related subjects that are required of any university graduate. However, to ensure formal education in areas of practice requiring knowledge of the Canadian accounting environment, legislation and standards, graduates of universities outside Canada must complete, at a Canadian university, the required courses in advanced financial accounting, taxation and law.

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