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Does My Ontario Non-Profit Need an Audit? ONCA Audit & Review-Engagement Thresholds 2026

Reviewed by Bader A. Chowdry, CPA, CA, LPA on

Quick answer: It depends on your corporation’s annual revenue and whether it is a “public benefit corporation” under Ontario’s Not-for-Profit Corporations Act, 2010 (ONCA). A public benefit corporation needs a mandatory audit once revenue reaches $500,000, needs at minimum a review engagement between $100,000 and $500,000, and can waive both below $100,000. Non-public-benefit corporations get a more relaxed track: waive both at $500,000 or less, review engagement required above that. Every waiver requires an 80% extraordinary resolution of the members.

What are Ontario’s ONCA audit and review-engagement thresholds in 2026?

Ontario’s Not-for-Profit Corporations Act, 2010 (ONCA) sets financial-review requirements based on two variables: your corporation’s annual revenue and whether it qualifies as a “public benefit corporation.” A public benefit corporation with revenue of $500,000 or more must have a full audit. Between $100,000 and $500,000, a review engagement is the minimum, though members can waive up to the audit by extraordinary resolution. At $100,000 or less, members can waive both. Non-public-benefit corporations get a lighter track: waive both at $500,000 or less, review engagement required above that — audits are never mandatory for this category.

The distinction matters because most incorporated charities and many donation-funded non-profits automatically fall into the public benefit category — and that category’s mandatory-audit line sits at the same $500,000 figure many boards assume applies to everyone. It doesn’t. A $480,000-revenue food bank that receives $15,000 a year from a municipal grant is a public benefit corporation under ONCA s.1(1)‘s test and is legally required to have at least a review engagement, not merely “encouraged” to.

Corporation type Annual revenue Required financial review
Public benefit corporation $100,000 or less Waivable — both audit and review engagement
Public benefit corporation More than $100,000, less than $500,000 Review engagement (audit itself is waivable)
Public benefit corporation $500,000 or more Audit — mandatory, not waivable
Non-public-benefit corporation $500,000 or less Waivable — both audit and review engagement
Non-public-benefit corporation More than $500,000 Review engagement (audit never mandatory)

What counts as a “public benefit corporation” under ONCA?

A public benefit corporation is any charitable corporation, or a non-charitable corporation that receives more than $10,000 in a financial year from either (a) donations or gifts from people who are not members, directors, officers, or employees, or (b) grants or similar financial assistance from a federal, provincial, or municipal government or government agency. This is a factual test applied every year — a corporation can flip in or out of public benefit status depending on that year’s funding mix.

This trips up boards constantly. A community sports association that is not a registered charity but received a $12,000 municipal recreation grant this year is a public benefit corporation for that fiscal year, full stop — even though last year, with no grant, it was not. Track this annually; don’t assume last year’s classification still applies. All registered charities are automatically public benefit corporations regardless of revenue source, since the definition captures “charitable corporation” outright.

How does the 80% extraordinary resolution audit waiver actually work?

Any waiver of an audit, or of both an audit and review engagement, requires an extraordinary resolution under ONCA — approval from at least 80% of the votes cast at a special members’ meeting (assuming quorum), or the written consent of all voting members. The waiver is not permanent: it is valid only until the corporation’s next annual meeting, so boards that want to keep waiving must re-pass the resolution every year. Directors who skip this step and simply decide internally not to bother with a review engagement are not in compliance with ONCA, regardless of revenue.

In practice, the resolution should be minuted, referenced in the AGM notice, and retained in the corporate records book alongside the by-laws — it is exactly the kind of document a CRA charity audit or an ONCA compliance review will ask to see first.

What happens if a corporation skips a required audit or review engagement?

Directors have a positive obligation under ONCA to arrange the appropriate financial review for the corporation’s revenue tier. Skipping a mandatory audit exposes directors to potential liability for breach of their statutory duties, can jeopardize charitable registration if the corporation is also a registered charity reporting to the CRA, and routinely surfaces during due diligence for grant applications, bank financing, or D&O insurance renewal — funders increasingly ask for the prior year’s audited or reviewed statements as a condition of the next grant cycle.

For registered charities specifically, the CRA does not itself mandate an audit at a fixed revenue threshold the way ONCA does — audit expectations for charities come from the province’s corporate statute (ONCA) and, separately, from funder or grant-agreement requirements. The two obligations run in parallel and neither substitutes for the other.

Who can actually perform the audit or review engagement?

Under the Public Accounting Act, 2004, only an individual holding a valid Licensed Public Accountant (LPA) designation from CPA Ontario is permitted to sign an audit report or a review engagement report in Ontario — a general CPA, CA designation on its own is not sufficient authorization to sign. This catches many boards off guard late in the process, after they’ve already engaged a firm. We cover this in detail, including how to verify a firm’s LPA status before engagement, in our companion guide on who can legally sign an audit report for an Ontario charity or non-profit.

Frequently asked questions

Does a small non-profit under $50,000 in revenue need any financial review at all?

Non-charitable corporations under $50,000 generally fall well under both the public benefit and non-public-benefit waiver thresholds ($100,000 and $500,000 respectively), so members can waive both audit and review engagement by extraordinary resolution. The corporation still needs financial statements prepared for the AGM — the waiver removes the external audit/review requirement, not the requirement to prepare statements at all.

Can a public benefit corporation waive the audit but still do a review engagement?

Yes. Between $100,000 and $500,000 in revenue, a public benefit corporation can waive the full audit by extraordinary resolution and substitute a review engagement instead — that is precisely what the middle tier of the ONCA chart allows. Below $100,000, both can be waived.

Does the $500,000 threshold reset every fiscal year?

Yes. The classification is based on the corporation’s revenue for that specific financial year, so a charity that grows past $500,000 for the first time triggers the mandatory-audit requirement for that year going forward, even if prior years qualified for a waiver.

Is a review engagement cheaper than a full audit?

Generally yes — a review engagement involves less audit evidence-gathering (primarily analytical procedures and inquiry rather than substantive testing) and is typically priced lower than a full audit for a comparable organization, though exact fees depend on the corporation’s transaction volume, fund structure, and prior-year documentation quality.

Sources

Related reading: our broader NPO & charity audit guide for Toronto/GTA organizations, a real case study on an Ontario NPO’s T3010 and reserve-fund audit, and our parent resource on non-profit and charity accounting & audit in Ontario.

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About the Author

Bader A. Chowdry, CPA, CA, LPA is the owner of Insight Accounting CPA Professional Corporation in Mississauga, Ontario. He is the firm’s only Licensed Public Accountant (LPA) — the designation the Public Accounting Act, 2004 requires to sign an audit or review-engagement report in Ontario — and works with charities, foundations, and non-profit boards across the GTA on ONCA compliance, T3010 filing, and disbursement-quota planning. Book a consultation.

Important — informational only, not advice. Do not use this article to make any decision.

This article is published by Insight Accounting CPA Professional Corporation for general educational purposes only. It is not tax, legal, accounting, financial, or investment advice, and nothing in this article should be relied upon — by anyone, for any purpose — to make a business, tax, financial, accounting, legal, or investment decision.

Tax law, CRA administrative positions, court interpretations, and Ontario provincial rules change frequently, sometimes retroactively, and the content of this article may be incomplete, simplified, out of date, or wrong by the time you read it. The right answer for your specific situation depends on facts this article does not know — your structure, history, jurisdiction, filings, contracts, and goals.

Before acting, engage your own Chartered Professional Accountant or qualified advisor who has reviewed your specific circumstances in writing. Insight Accounting CPA Professional Corporation, the author, and any contributors expressly disclaim all liability — direct, indirect, or consequential — for any action taken or not taken on the basis of this content.

Insight Accounting CPA Professional Corporation is led by Bader A. Chowdry, CPA, CA, LPA — licensed by CPA Ontario under the Public Accounting Act, 2004. To engage us for situation-specific advice, book a free 30-minute discovery call.


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