Frequently asked questions – Ethical issues to consider during the COVID-19 pandemic

The current situation is causing us all to manage unusual situations in the workplace. For CPAs, there are a number of impacts, in particular with regard to government measures and clients’ requests in reaction to these measures. Despite the crisis, CPAs must follow the rules of professional conduct governing the profession, even if that means adapting their ways of doing things.

Last updated: January 18, 2021

What are my professional obligations in a crisis context?

Regardless of whether you are working remotely, at your office, or a combination of the two, you must comply with the government health directives  at all times. As failure to abide by these directives could raise questions about your professional liability, from both the civil and disciplinary standpoints, we recommend that you document the different measures implemented by your firm or organization. We recommend creating a file with all of the relevant information sent to your personnel and clientele regarding compliance with government directives (emails, notices, meeting agendas, remote work planning, memos for clients, etc.).

My employer or my client is asking me to assist with government subsidy applications. Which of my professional obligations should I be mindful of? 

During the COVID-19 crisis, both federal and provincial governments are helping individuals, businesses, not-for-profit organizations, and other enterprises through several grant and subsidy programs. As a result, CPAs are often being asked by their employer or clients to provide guidance as to their eligibility to these programs or to prepare application forms to receive these benefits on their employer’s or clients’ behalf.

When providing such assistance, you must always be mindful of the following Code of Ethics requirements: 

Article 19 – Compliance with professional standards
As a CPA, you are required to perform professional services with due care, in keeping with current applicable standards and with current scientific knowledge.

Article 23 – Integrity and objectivity
Article 23 requires CPAs to perform professional services with integrity and not allow their professional or business judgment to be compromised by bias, conflict of interest, or the undue influence of others. As an entity’s eligibility for COVID-19-related programs might rely on revenue reductions or other thresholds, it is crucial that you be careful not to allow clients or employers to unduly influence your professional judgement.

Article 34 – Avoiding false or misleading documents and representations
You might be preparing letters, reports, statements, representations, or financial statements to assist your employer or clients with COVID-19-related government programs. When doing so, you must remember not to sign, prepare, produce or even associate your name with any letter, attestation, opinion, report, statement, representation, financial statement or other document, which you know, or should know, contains false or misleading information, out of complacency or without ensuring that such documents are in compliance with good practices or current scientific knowledge.

Finally, you might need to educate your employer or clients regarding the nature of these government programs and the related tax treatment to avoid cash flow difficulties down the road. Whilst COVID-19 government-related benefits and programs can greatly assist clients and employers in a time of financial crisis, you must apply caution and maintain CPA ethical standards when assisting them in determining their eligibility.

I am a partner in a firm or I am a sole-practitioner. Are there any preventive measures that I need to put in place?

Yes. As soon as possible, designate a replacement CPA to cover for you if you become unable to work — for example, if you contract COVID-19. As a CPA, you are responsible for making the necessary arrangements for your clients to have a contact person in the event of an emergency. Although this is easier in a firm with several CPAs, it is also possible if you work alone. Without having to take over your client base, your replacement will at least be able to notify your clients so they can make informed decisions about their current files. Please note that you should always have this type of arrangement to be prepared for any situation that could prevent you from working, and not just during a crisis. 

For more details, see the article “Being Available and Diligent for Your Clients is a Winning Strategy.”

Can I sign notices to readers and review and audit reports to help out another CPA?

It’s possible, but you have to adhere to the current rules and standards, as required under Section 19 of the Code of ethics. For example, in the case of an audit engagement, even if you carefully reviewed the client’s file and suggested corrections before signing your report, the standards are clear regarding the need for you be familiar with the client’s affairs. You must therefore carefully document what you have done to have sufficient knowledge of your client’s affairs. Among other things, you may have spoken with the engagement team members about the client’s financial position and the risks faced by the client’s business, and/or had one or more conversations with the client or the client’s accounting personnel. 

In all cases, signing a report in non-compliance with the standards, even though they are less stringent in the case of a compilation engagement, is a highly risky practice that must be strictly avoided. Under Section 34 of the Code of ethics, such a signature could be considered as complacency and render you liable to a disciplinary complaint.

You must also be sure to use appropriate stationery for the situation (engagement letter, report, etc.).

If you are not currently practicing public accountancy, you should contact the professional practice support team to confirm what the conditions are for helping out another CPA by performing one or more of the tasks mentioned. 

T. 514-288-3256 [2611]  1-800-363-4688
Can I ask my client to pay fees in advance?

Yes, you may hold amounts or property on your client’s behalf, including advances on fees. These advance payments must, immediately after receipt thereof, be deposited in a trust account. See sections 1 and 4 of the Regulation respecting trust accounting.

Therefore, before asking your client to pay fees in advance, you must have a trust account where you can deposit the advance payments. You may use such amounts only for the purposes for which they were entrusted to you. In other words, you may not use the funds to pay an invoice submitted for costs incurred or services rendered on behalf of the same client. For example, amounts held in trust may under no circumstances be used to pay the firm’s current accounts. 

Remember that under Section 56 of the Code of ethics, you may never require full advance payment for your services.

To open a trust account, contact your financial institution. Given the exceptional circumstances surrounding the coronavirus (COVID-19) pandemic, you may have to apply online to open the account. Be sure to specify that you want to open a trust account, not a commercial account. 

When you open the trust account, you also have to complete a trust account opening form and submit it to the Order and the financial institution. 

For more details, see the Trust Accounting page.

If you have questions about trust accounts, please contact the Member Support team by email at or by telephone at 514-288-3256, extension 2630 (or toll free at 1-800-363-4688).

Can I stop providing services for clients who are no longer able to pay me due to the current crisis?

The exceptional situation created by the COVID-19 pandemic does not change the rules governing cessation of services set forth in sections 52 and 53 of the Code of ethics.

Even if a client owes you a huge amount or there is a risk of the client not paying you because of the impact of the health crisis on the client’s business, you may not ignore or stop answering the client or even terminate your assignment. 

Although Section 52 identifies the refusal by the client to recognize an obligation for your professional fees or, after being given reasonable notice, to pay you an amount to cover such fees as a good and sufficient reason for ceasing to act on behalf of a client, you need to keep in mind that Section 53 stipulates that before ceasing to act on behalf of a client, you have to give the client reasonable advance notice of withdrawal and make sure that the withdrawal will not prejudice the client. 

Reasonable advance notice of withdrawal depends on several factors and the specific situation. Aspects such as the following have to be taken into account, as applicable:

  • Bookkeeping engagement: timeframes for returns that have to be submitted in the short term, payroll support, complexity of tasks
  • Audit engagement: date of the inventory count, period of the year when the audit is conducted, pool of CPA auditors able to conduct the audit in the case of an industry with specific regulatory requirements, timeframe for submitting the audited financial statements to the bank or regulatory authority
  • Personal income tax return engagement: mainly the timeframe for filing

To determine whether ceasing to act on your client’s behalf could prejudice your client, you need to take into consideration factors such as the client’s ability to find another CPA to replace you. It goes without saying that clients in financial difficulty will probably find it hard to find a CPA to audit their financial statements or keep their books for the current year. In addition, if you have already begun your engagement with your client, it will be even harder to show that you have not prejudiced the client if the only reason for ceasing to provide your services is non-payment of your fees. 

In short, before ceasing to act on behalf of a client, send the client a notice of withdrawal, keep all proof that the advance notice of withdrawal you provide the client is reasonable and document the measures you take to avoid prejudicing the client. 

For more details, see the article “Being Available and Diligent for Your Clients is a Winning Strategy.”

What is a reasonable time period for answering my clients given the large volume of calls related to COVID-19?

Under Section 50 of the Code of ethics, you must display reasonable availability and diligence in the practice of your profession. But what is considered reasonable under the current circumstances? The best way to answer this question is to put yourself in your client’s shoes. In this situation, you would certainly be concerned if the CPA you do business with were to dodge or not return your calls. So, if you are swamped with requests, don’t hesitate to activate automatic voicemail and email messages informing your clients about the unusually high volume of requests that you have to process. 

For more information about your obligation to be available and diligent, see the article “Being Available and Diligent for Your Clients is a Winning Strategy.”

The government has announced a large number of measures to manage the COVID-19 crisis, and my clients are asking me to help them, even though the terms of application are sometimes uncertain. What should I do?

Despite how quickly the situation is evolving, you must not lose sight of your ethical obligations. As a CPA, what you say has value and is certain to influence your clients and the way they conduct their affairs. Your clients rely on the opinions and advice you give them not only in writing but also verbally. To avoid problems, you must therefore always act with competence and due care, within the meaning of Section 19 of the Code of ethics.

You need to make sure that the information you want to share comes from a reliable source and, if there is room for interpretation, advise your clients about the various possible scenarios. In all cases, as specified in Section 16 of the Code of ethics, consider the extent of your proficiency and the means at your disposal and, in case of doubt, don’t hesitate to encourage your clients to consult another professional.

For more details, see the article “What You Write and Say Matter!

Given the COVID-19 pandemic, is it acceptable to ask my clients to leave their documents in a box at the door to my office?

It goes without saying that you must not ask your clients to leave their documents at the door of your office while no one is there. Set specific times for receiving documents or ask your clients to use email, a secure portal or registered mail. If you ask your clients to send you their documents by email, be sure to read the rest of these FAQs to find out how to proceed securely.

Given the COVID-19-related risks, can I opt for email instead of meeting my clients in person?

Yes, email is a good way to reduce physical contact and comply with the government health directives.  However, it is important that the email be secure, in order to protect the confidentiality of the information shared.

You can protect the sensitive data you exchange by using encryption and a password. To find out more, see page 29 of the CPA Guide on Best Practices in IT Use. You can also use a secure document storage and sharing cloud service like Docurium. This platform is part of a service offer negotiated by the Order along with the Barreau du Québec and the Chambre des notaires. 

Also make sure that you have obtained your clients’ authorization to email documents protected by professional secrecy. At the same time, validate the email address your clients want you to use.

To find out more about CPAs’ use of email, see the article “Email: Can Efficiency and Quality Go Hand in Hand?

Given the risk of spreading COVID-19, do I have to provide clients who insist on receiving hard-copy documents?

Pursuant to Section 46.1 of the Code of ethics, you must promptly return documents to your client or your client’s representative. You may nevertheless explain to the client that sending documents electronically is preferable in the current context, for your mutual safety and that of your respective teams. Despite everything, if your client insists on hard-copy documents, make sure you abide by the government health directives  and keep proof that you have tried to convince the client to agree to electronic transmission of the documents.

Can I use social media to circulate information during the crisis?

Yes, but keep in mind that as a CPA you must at all times be prudent, professional and show restraint in using social media. This is particularly vital during the current crisis, when communication is especially important for maintaining relations with your clients. To avoid blunders, see the article “5 Useful Tips to Help You Avoid Social Media Gaffes.”