CPA Members Working for Non-Registered Firms

Last Revision: 5/13/2021
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As a CPABC member, if you are contemplating working for a non-registered firm that offers public accounting, there are a number of considerations you should be aware of.  One important consideration, association, is covered in this document.    


When entering into such a business relationship, whether as an employee or contractor, it’s important to understand your responsibilities as a CPABC member and the rules governing association with non-members.

A CPABC member is responsible for the conduct of non-members in the firm and could be held accountable for breaches of the CPABC Code of Professional Conduct (the “Code”) by these non-members.  This is contained in the Rule 408 – Association with non-registrant in public practice and 406 – Responsibility for a non-registrant.

408.1: A member or registered firm shall not associate in any way with a non-registrant in a practice of public accounting, or in a related business or practice, unless such association maintains the good reputation of the profession and serves the public interest; and such business or practice establishes and maintains policies, procedures and arrangements suitable for ensuring that every such non-registrant is knowledgeable of and complies with CPABC’s governing legislation, bylaws, regulations and Code; and the ethical and other regulations applicable to members of a recognized professional organization or regulated body of which the non-registrant is a member; and no style or presentation or communication is used which implies that the non-registrant is a registrant.

406.1: A member or registered firm engaged in the practice of public accounting who is associated in such practice with a non-registrant shall be responsible to CPABC for any failure of such non-registrant, in respect of all areas of practice of the member or firm, to abide by the CPA Code and in the application of this Rule, the CPA Code is deemed to apply as if such non-registrant were a registrant.

A CPABC member working in a non-registered public practice firm could be held accountable for any breaches by non-members of the non-registered firm. Taking this into consideration, a CPABC member should consider the professional capabilities of the non-members they will be working with.  This includes assessing their qualifications, technical skills, reputation, competence and integrity. 

While a CPABC member can work on client files at the non-registered firm they cannot be engaged in public practice while working at a non-registered firm. Public practice is defined in Bylaw 100 and it can include, but is not limited to, the CPABC member performing a final review of the files and signing off on files.  Also a CPABC member must not have, nor be perceived to have, overall engagement responsibility in any of the activities included in the definition of public practice. It is also important to consider how the CPABC member is perceived by clients of the non-registered firm so as to not be misleading the public. 

For the reasons above a CPABC members should ensure that there is a contract between themselves and the non-member firm clearly outlining their role and responsibilities at the firm.  Legal advice might be considered.  It is also important to consider if the non-member firm has adequate professional liability insurance and the extent of this coverage.

Navigating these rules can be tricky and each situation is unique.  For further guidance, members can contact

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