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Letter to Hon. Madeleine Meilleur re: Accounting professions legislation

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February 24, 2015

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Hon. Madeleine Meilleur
Attorney General of Ontario
11th Flr 720 Bay St
Toronto ON  M7A 2S9

Dear Minister,

Re: Accounting professions legislation

It has come to the attention of the Ontario Human Rights Commission that the Ontario Government is looking at making changes to the statutes dealing with the Certified Management Accountants of Ontario, the Certified General Accountants Association of Ontario and the Institute of Chartered Accountants of Ontario in recognition that these bodies have effectively unified under the banner Chartered Professional Accountants.

I understand that the Ministry of the Attorney General is hearing from groups such as the Chartered Institute of Management Accountants – United Kingdom (Canada branch), the Canadian Centre for Diversity and Inclusion, and the Toronto Region Immigrant Employment Council, who have raised concerns that current legislative restrictions on the use of international accounting designations have an adverse discriminatory effect on access to employment based on place of origin and related grounds under Ontario’s Human Rights Code.

As you are aware, in 2013, the Ontario Human Rights Commission released its Policy on removing the “Canadian experience” barrier. The Policy recognizes that internationally trained professionals experience many barriers to finding jobs including employers not recognizing foreign credentials and experience. The Policy says that governments, regulatory bodies and others have a role to play to identify and remove barriers.

While consumer protection is an important goal, provisions restricting the use of international accounting designations should be reviewed to make sure they are bona fide and reasonable. Moreover, the pending legislative change should aim more broadly to avoid adverse effect on internationally trained accountants living and working in Ontario.

The requirements that regulatory accounting bodies set for assessing and using international designations, as well as licensing internationally trained accountants under an Ontario designation, including any mutual recognition agreements with other professional bodies, also need to be bona fide and reasonable and inclusive as possible. Even so, there is still a duty to accommodate individual differences, based on place of origin and other grounds, up to the point of undue hardship.

As you know, I’m leaving the Commission at the end of February. Staff at your Ministry are welcome to contact Jeff Poirier, Senior Policy Analyst at the Commission at 416-314-4539, if there are any questions.

Yours truly,

Barbara Hall, B.A, LL.B, Ph.D (hon.)
Chief Commissioner


Martin Saxton, Chair
Chartered Institute of Management Accountants Canada

Michael Bach, CEO
Canadian Centre for Diversity and Inclusion

David McKay, Chair
Toronto Region Immigrant Employment Council

Michael K. Banks, Chair
Chartered Professional Accountants of Ontario

Jean Augustine, Fairness Commissioner
Office of the Fairness Commissioner of Ontario