Guide · Tax preparers

What a tax preparer
may advertise.

You do not need a CPA licence to prepare tax returns for a fee in Ontario. You do need to watch what you call yourself, what you say about the Canada Revenue Agency, and how you describe refunds and prices. Those rules sit in two Ontario statutes, three federal ones and CRA's own EFILE terms.

Published 2026-11-04 · Formory Marketing Group

The Public Accounting Act, 2004 requires a licence only for public accounting. Section 2 defines that as independent assurance work, such as audits and review engagements on financial statements that a third party is expected to rely on, and compilations a third party is expected to rely on, unless the compilation carries the prescribed notice limiting assurance to the arithmetic.

Section 3(3) then says no licence is needed for bookkeeping, or for preparing financial statements solely as part of tax returns, as long as you offer no opinion independent of the taxpayer on those statements or returns, and no other service that needs a licence. That is the space a tax preparation business works in.

So a services page can list personal and small business returns, bookkeeping and payroll. It should not list audits, review engagements or "financial statements for your bank" unless a licensed public accountant does that work. Section 37 adds that nobody can recover fees charged as a public accountant without a licence.

Section 29 of the Chartered Professional Accountants of Ontario Act, 2017 reserves for CPA Ontario members the titles Chartered Professional Accountant, Chartered Accountant, Certified Management Accountant, Registered Industrial Accountant and Certified General Accountant, and initials such as CPA, CA, CMA, CGA and RIA, whether used alone or mixed with other words. It also bars any term implying you hold one of them, and practising as a CPA. The ban covers individuals acting "through an entity", and corporations other than CPA professional corporations, so a business name or Google listing name is caught too. Section 30 sets fines of up to $10,000 for a first offence and $25,000 after that.

The exceptions for qualifications earned outside Ontario are narrow: a talk at a professional or academic conference, a job application or private communication about a retainer in which you expressly say you are not a CPA Ontario member, and a response to a request for proposals. A website is not on that list. The Act also says that adding the country's name after the title does not count as saying you are not a member.

The Public Accounting Act separately protects "Public Accountant", "Licensed Public Accountant" and "LPA", and their equivalents in any other language, with fines of up to $25,000 and then $50,000 under section 13. If your site has pages in Punjabi, Tagalog or Chinese, the translated title is covered.

Section 29 does not list the plain word "accountant". Because any term implying a CPA is barred, the safer wording is the one that says what you are: "tax preparer" or "bookkeeper". CPA firms have their own advertising code, covered in our guide for CPA firms.

CRA's EFILE eligibility page has a short section headed "In your advertising". Processing times you quote for an e-filed return or refund must match CRA's own time frame: as little as eight business days. You cannot imply a special relationship with CRA or an endorsement by it, or use CRA's signature or marking. You cannot use the words "authorized" or "agent". Anything public that refers to EFILE cannot be false or misleading. To use part of a CRA guide, return or schedule in an ad, you must ask CRA for approval first and send a sample.

That rules out a common line: "CRA-authorized e-file agent" breaks two rules in four words. A CRA logo in the header or a picture of a CRA form on the homepage needs the same caution. CRA lists violation of its advertising standards among the grounds for suspending EFILE privileges.

What you can say is what is true: you file returns electronically through CRA's EFILE service. CRA's own name for the role is EFILE service provider.

Under section 150.1 of the Income Tax Act, a tax preparer is a person or partnership who accepts payment to prepare more than five individual, corporate or trust returns in a calendar year. An employee preparing returns as part of their job is not one. A tax preparer must e-file the returns they prepare for a fee, except five of each type. CRA's mandatory electronic filing page says this applies from January 1, 2024.

The penalty, in section 162(7.3), is $25 for each individual return and $100 for each corporate return filed on paper when it should have been e-filed; CRA applies the $25 to trust returns too. The main exceptions are returns of a type CRA does not accept electronically and preparers whose EFILE application was refused or whose privileges were suspended.

One more EFILE term matters if you advertise "we e-file your return for you" to people who prepared their own. CRA says that if you offer transmission services to clients who prepare their own returns, it treats you as the tax preparer, with all the responsibilities that come with it, including Form T183.

Paying a client cash now in exchange for their tax refund is discounting under the Tax Rebate Discounting Act. Section 2 sets the minimum you must pay: 85% of a refund of $300 or less, or $255 plus 95% of anything over $300. Section 3(2) says the discount includes your fee for preparing the return and any other directly related service, so a separate preparation fee on top is an offence. CRA's information for discounters repeats that extra fees are not allowed and lists the only two deductions it accepts administratively.

Section 4 requires payment by cash or cheque at or before the time you acquire the refund, a signed statement (Form RC71), and a copy of the return if the client asks. If CRA pays out $10 or more above your estimate, the client gets the difference. Discounters need an EFILE number and a discounter code for each location. Offences carry fines of up to $25,000 under section 7, and section 6.1 makes it an offence to knowingly give a client false, misleading or incomplete information about a discounting transaction.

CRA's public page shows what the numbers look like: on a $1,000 refund, the client receives $920 and the fee is $80. An honest ad says roughly that. "Get your full refund today" does not.

The federal Competition Act treats a misleading representation to the public as reviewable conduct, and section 74.01(1.1) says a price that cannot be paid because of fixed obligatory charges is misleading, unless the extra amount is only a tax or charge imposed by law. "Returns from $39" followed by a mandatory e-file or processing fee is the pattern it describes. HST can be added; your own fees cannot be held back until checkout.

If you show a crossed-out "regular" price, section 74.01(3) expects that you actually sold a substantial volume at that price, or offered it in good faith for a substantial period. For how to lay out a price list, see how to show prices on your website.

On the about page, your name and what you are: a tax preparer or bookkeeper, with no protected title in any language and no foreign designation shown as a credential. On the services page, returns and bookkeeping, and no audits or review engagements. On the fees page, the full price of each service with HST noted, and, if you discount refunds, the 85% and 95% minimums with your fee included. Refund timing in CRA's words. No CRA logo and no "authorized" or "agent". Keep the Google listing name and ads to the same wording. Our notes on websites for tax preparers cover the rest.

This is a plain summary of the statutes and CRA pages listed below as of November 2026, not legal or tax advice.

• Public Accounting Act, 2004, S.O. 2004, c. 8 — sections 2, 3, 13 and 37
• Chartered Professional Accountants of Ontario Act, 2017 — sections 17, 18, 29 and 30
• CRA — EFILE eligibility, responsibilities and advertising
• CRA — Mandatory electronic filing for tax preparers
• Income Tax Act — section 150.1 (2.2)–(2.4)
• Income Tax Act — section 162 (7.3)
• Tax Rebate Discounting Act, R.S.C. 1985, c. T-3 — sections 2 to 7
• CRA — Information for discounters
• CRA — Discounter information for individuals
• Competition Act — section 74.01

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CPA Advertising Rules in Ontario: What Your Firm Website May Say · Showing Prices on Your Website in Canada: Drip Pricing Rules · How to Register a Business Name in Ontario: $60, Five Years

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