Who Can Legally Sign an Audit Report for an Ontario Charity or Non-Profit?
Reviewed by Bader A. Chowdry, CPA, CA, LPA on
Quick answer: Only an individual holding a valid Licensed Public Accountant (LPA) designation from CPA Ontario, under the Public Accounting Act, 2004, may legally sign an audit report or a review-engagement report for an Ontario charity or non-profit. A CPA, CA, or CPA, CGA designation alone is not sufficient — public accounting licensure is a separate credential on top of the base CPA designation, and a meaningful share of practising CPAs in Ontario do not hold it.
Who can legally sign an audit or review-engagement report for an Ontario charity or non-profit?
In Ontario, the Public Accounting Act, 2004 restricts the practice of public accounting — which includes signing audit reports and review-engagement reports — to individuals who hold a Licensed Public Accountant (LPA) licence issued by CPA Ontario, and who are independent of the entity being audited or reviewed. This applies whether the organization is a registered charity, a non-charitable non-profit, or any other entity requiring an audit or review engagement under ONCA. Simply being a CPA — even a CPA, CA with decades of tax and advisory experience — does not, on its own, authorize a person to sign these reports. Engaging in public accounting without an LPA licence is a statutory offence.
This is the single most common gap we see boards discover late: they’ve already engaged an accountant, sometimes for months, before realizing the report can’t actually be signed and filed because the practitioner isn’t licensed for public accounting. It is worth confirming before engagement, not after the fieldwork is done.
Why isn’t a regular CPA designation enough?
The base CPA designation (including legacy CA, CGA, and CMA designations that merged into CPA) qualifies a person for a very wide range of accounting, tax, and advisory work. Public accounting — specifically, signing audit opinions and review-engagement reports that third parties (funders, regulators, banks, the CRA) rely on — is treated as a higher-stakes activity requiring its own licence. To obtain a PAL, a CPA must complete additional practical experience requirements on top of standard certification, including a minimum of 2,500 chargeable hours in public accounting and other qualifying services, of which at least 1,250 hours must be in assurance engagements specifically. Many CPAs in tax, corporate finance, industry, or advisory roles never complete this additional pathway because their practice doesn’t require it — which is exactly why the license exists as a separate gate.
How does a non-profit board actually verify a firm’s LPA status?
CPA Ontario maintains a public, searchable Public Accounting Licence Directory that any board, treasurer, or executive director can use to confirm a specific individual holds a current LPA licence before signing an engagement letter. This takes minutes and should be a standard step in any audit or review-engagement RFP process — alongside confirming independence (no board seat, no material financial relationship, no family connection to key management) and confirming the firm’s own registration with CPA Ontario if applicable.
What happens if a report is signed by someone without an LPA licence?
A report signed by an individual who is not licensed under the Public Accounting Act, 2004 is not a valid audit or review-engagement report for the purposes that require one — it will not satisfy the ONCA financial-review requirement for the corporation’s revenue tier, and funders, banks, or regulators that specifically require an audited or reviewed statement can reject it outright. Beyond the compliance exposure, the individual performing the engagement without a licence is themselves exposed to regulatory action by CPA Ontario. This is a real, if under-discussed, risk in the sector: non-profits often select an accountant based on an existing relationship or lowest fee, without confirming licensure, and only discover the gap when a grant application or bank covenant is rejected for want of a properly signed report.
Frequently asked questions
Is a CPA, CA automatically also a Licensed Public Accountant?
No. CPA, CA is the base professional designation. LPA is a separate, additional licence issued by CPA Ontario under the Public Accounting Act, 2004, requiring extra practical experience in public accounting and assurance work. A CPA, CA without a current LPA licence cannot sign an audit or review-engagement report.
Does a review engagement have the same signing requirement as a full audit?
Yes. Both audit reports and review-engagement reports fall under the Public Accounting Act, 2004’s definition of public accounting, so both require a currently licensed LPA to sign, regardless of which tier your organization’s ONCA revenue band requires.
Can a bookkeeper or unlicensed accountant prepare our financial statements even if they can’t sign the audit?
Yes — preparing financial statements (compilation-level work) generally does not require a public accounting licence. The licence requirement is specifically tied to signing audit opinions and review-engagement reports, not to bookkeeping or statement preparation. Many non-profits use an in-house or outsourced bookkeeper for day-to-day records and a separately licensed LPA firm for the annual audit or review.
How do we confirm a firm is properly licensed before signing an engagement letter?
Search the individual’s name and, if applicable, the firm’s name in CPA Ontario’s public Public Accounting Licence Directory before signing any engagement letter. This single step prevents the entire class of problem described above.
Sources
- CanLII — Public Accounting Act, 2004, S.O. 2004, c. 8 (full text)
- CPA Ontario — Public Accounting Licence requirements
- CPA Ontario — Public Accounting Licence Directory (verify a licensee)
- Ontario.ca — Rules for not-for-profit and charitable corporations (ONCA financial review requirements)
Related reading: our guide to ONCA audit & review-engagement thresholds, the broader ONCA compliance requirements checklist, our 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.
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.
