1. Transitioning to the new Practical Experience Requirements
Transition rules are set out in CA Practical Experience Requirements (PER), Section 1.4.1.
Purpose
The purpose of the transition rules is to provide Approved Training Offices (ATOs) as defined in section 1.4.1.1 of the PER with a reasonable period in which to adjust their existing systems for training students and reporting to the profession, and to provide clarity around which rules apply to CA Students registered before September 1, 2009.
Requirements
- The CA Practical Experience Requirements apply to all CA Training Offices for all CA Students in Canada and Bermuda who register with a Provincial Institute/Ordre/Region on or after September 1, 2009.
- All CA firms (including Offices of the federal and provincial Auditors General and the Auditor General of Bermuda) that were already recognized as Approved Training Offices and employing CA Students prior to September 1, 2009 were “grandparented” — i.e., automatically approved — as CA Training Offices (CATOs) under the new requirements for CA Student positions in public practice. For approval for new positions outside the traditional public practice path, such as taxation or business advisory services, speak with your regional CATO Liaison.
- All CA Students registered before that date can elect, with the support of their employer, to qualify under the new requirements or under the requirements in effect at their date of registration.
- All CA Training Offices are required to have a CA Training Program (see Section 3: Approved CA Training Programs) approved by their Provincial Institute/Ordre. In the transition period, the traditional public practice path of CA Students is approved as a grandparented CA Training Program.
- Grandparented CA Training Offices will continue to be subject to periodic review by their Provincial Institute(s)/Ordre.
Q. Are there any significant differences between the practical experience requirements that are effective as at September 1, 2010 compared with the practical experience requirements that came into effect on September 1, 2009?
A. There are two primary differences:
- Modifications to depth and breadth requirements which will allow greater flexibility for both employers and students while maintaining the standards and rigor currently required from all CA Training Offices. These changes need not affect your existing programs or CA students.
- Clarified descriptions of the specific competencies to reflect more accurately the competencies expected of an entry-level CA. These changes required updates to the Record of CA Qualifying Experience (RQE). We suggest you encourage all CA students currently completing the RQE to transition to the new version, though there is no requirement to do so.
It should be noted that any approved CATO positions and career paths that were approved under the 2009 PER meet the requirements of the 2010 PER.
Q. For ATOs that were grandparented, what’s the primary impact of the PER changes that came into effect on September 1, 2009?
A. Grandparented CA Training Offices continuing to train students for public practice will find minimal change to their existing processes for training CA Students, the work they assign to them, and their processes for reporting to the profession as the new requirements are based on the best practices of these firms. The most significant changes are:
- Approved CA Training Program: All CA Training Offices are required to have a CA Training Program approved by their Provincial Institute/Ordre. The training processes provided by grandparented CA Training Offices meet all new practical experience requirements. There are, however, new supervisory and reporting requirements which grandparented CA Training Offices will be required to meet for all CA Students registering with a Provincial Institute/Ordre after September 1, 2009.
- Formalized supervision structure: The new requirements identify three distinct supervisory roles required to develop a CA Student: a Training Principal, Counselling Member and Line Manager. (See Section 8: Supervising CA Students.) This model is based on current practice and the same CA can fill more than one role. In some CA Training Offices the same CA may fill all three roles.
- Record of CA Qualifying Experience (RQE): All CA Students will be required to maintain a Record of CA Qualifying Experience documenting their development of CA competencies. CA Students are expected to maintain their RQE throughout their period of practical experience and to have it available for review by the Provincial Institute/Ordre/Region for a minimum of one year post-certification. (See Section 11: The Record of CA Qualifying Experience.)
- Regular meetings between the Counselling Member and CA Student: Counselling Members are required to meet with their CA Student(s) to discuss their development of CA competencies on a semi-annual basis throughout the employment period. (See Section 9: Semi-annual meetings between Counselling Members and CA Students.) Documentation indicating these meetings have taken place should be maintained by the CA Training Office for review by the profession.
- Specific hour and related reporting requirements to practise public accounting have not changed. (See Section 6: Practical experience requirements for the practice of public accounting.)
Q. What requirements apply to CA Students employed before September 1, 2009?
A. CA Students registered with a Provincial Institute/Ordre/Region and who began employment in a CA Training Office before September 1, 2009 can, in consultation with their employer, continue to acquire their practical experience under requirements in effect at the time of their registration OR transition to the new requirements. The previous requirements were based solely on prescribed chargeable-hour requirements in assurance services (including audit) and taxation services within the required 30-month work term (24 month-term in Quebec.) CA Student registration dates are usually the same as the first day of work with the CA Training Office. Contact the applicable Provincial Institute/Ordre/Region for further information on these requirements.
Q. What requirements apply to summer students and co-op students who began accumulating their practical experience before September 1, 2009?
A. If a summer student or a co-op student registered with their Provincial Institute/Ordre/Region and accumulated some practical experience before September 1, 2009, they will likely continue to acquire their practical experience under the requirements in effect at the time of their registration. However, if a summer student or a co-op student registered with their Provincial Institute/Ordre/Region prior to September 1, 2009 but commenced employment after that date, then the new Practical Experience Requirements would apply. Note: The process and timing of registration is different across Canada. Contact your Provincial Institute/Ordre/Region for more information.
Q. Can a CA Training Office choose to transfer all its students to the new requirements effective September 1, 2009?
A. This is only possible if all CA Students agree, since CA Students have the right to finish their experience under the requirements in effect at their date of registration.
Q. What are the rules for transitioning the experience of a CA Student who started under the prior requirements to the new requirements?
A. There is no requirement to transition students to the new requirements, and both the CA Training Office and all affected CA Students would have to agree to such a transition. The profession is willing to work with any CA Training Office considering such a transition.
Q. All CA Training Offices are now required to have an approved CA Training Program. What CA Training Program is approved for grandparented CA Training Offices?
A. Having an approved CA Training Program is not a NEW requirement. Grandparented CA Training Offices would have had, as an ATO, an approved CA Training Program for CA Students seeking traditional public practice experience. For grandparented CA Training Offices an approved CA Training Program comprises all aspects of that traditional public practice experience, including the prescribed minimum chargeable hours of their Provincial Institute/Ordre. Minimum chargeable-hour requirements include:
- At least 2,500 Chargeable Hours of practical experience, of which at least 1,250 Chargeable Hours are on Assurance Services assignments, of which 625 Chargeable Hours must specifically be on Audit Engagements; and
- An additional minimum of 100 Chargeable Hours in Taxation Services.
Contact the applicable Provincial Institute(s)/Ordre/Region for further information.
Q. Are grandparented CA Training Offices required to document current grandparented programs to demonstrate that they meet new competency-based requirements?
A. No, grandparented CA Training Offices are not expected to document their grandparented CA Training Programs because their training processes meet all required elements of the new practical experience requirements. They must, however, meet the new supervisory requirements, which include meeting with each CA Student at least twice per year to discuss performance and competency development.
Q. What will the assessment of potential new CA Training Offices involve?
A. Assessment will be based on the responsibilities and commitments of a CA Training Office (CA Practical Experience Requirements, Section 2.4.1), including:
- Senior management support of the CA Training Program;
- Characteristics of your firm to support CA training (such as learning policies, code of conduct, etc.)
- Ability of the program to provide CA Students with sufficient opportunity to develop the required CA competencies;
- Supervisory structure; and
- Tracking and reporting CA Student development to the profession.
To find out more about training CA Students outside of the traditional public practice career path, please contact your regional CATO Liaison.
Q. How does a grandparented CA Training Office apply to hire a CA Student directly into taxation or business advisory services?
A. CA Training Offices wishing to provide CA Students practical experience in new positions other than the traditional public practice path should contact their regional CATO Liaison. Your regional CATO Liaison will assist you with the application process.
Q. Many CA Firms hire students into their tax practices, and provide them with an audit rotation to ensure they get the required audit hours to practise Public Accounting. Does this now require separate approval?
A. No. Such rotations are simply a variation on the path for CA Students seeking to practice Public Accounting, and approval of these programs is grandparented. Only career paths that are not intended to lead to the practice of Public Accounting during the period of practical experience would require approval under the new expanded experience requirements.
Q. Will the experience of a CA Student gained in a CA Training Office awaiting approval for a position not leading to public practice be recognized?
A. Yes. CA Student experience accumulated during the approval period will receive pre-registration credit as long as it meets the criteria required for recognition of that experience. Speak with your regional CATO Liaison to understand the process and required documentation.
Q. When a CA Training Office approved to train CA Students in public practice receives additional approval to train in other areas (such as tax), can registered CA Students working in that other area prior to the approval be transferred into the newly approved area? Will the CA Student’s prior experience be counted towards the new area?
A. Generally yes, as long as the CA Student has been developing the required depth and breadth of CA competencies in the other area. Contact your Provincial Institute/Ordre for approval to switch these CA Students from public practice into the new area, and for approval of their applicable work experience.