Incorporation for a CPA Accountant in Quebec (2026): The New Regulation Explained
A CPA can incorporate in Quebec — and the rules just changed. Since April 16, 2026, a new regulation with three regimes replaces the former regulation on practising through a corporation. Only firms offering certification or compilation engagements must be controlled by CPAs (or an expanded group of professionals); tax, advisory and bookkeeping: no particular ownership requirement.
This guide explains the three regimes, the reserved acts, the case of the non-CPA bookkeeper, insurance, the taxation of an incorporated accounting firm, and the steps in the right order. Be wary of the rest of the web: most online content still describes the former regulation.
Each order has its own rules for practising through a corporation: see our guides for the incorporated physician and for health professionals. Economic activity code (CAE) to declare with the Registrar: 7731, 7732 or 7739 depending on your practice — see our CAE code search tool.
The CPA regulation was replaced on April 16, 2026 — and almost no one noticed
Since April 16, 2026, the Regulation respecting the practice of the chartered professional accountant profession within an organization replaces the former regulation on practising "through a corporation" (RLRQ, c. C-48.1, r. 16). Approved by the Office des professions (Decision OPQ 2026-991), it was published in the Gazette officielle du Québec on April 1, 2026. Any page that still cites the former regulation as current law is out of date.
This replacement stems from Bill 67 (L.Q. 2024, c. 31): the recast Chapter VI.3 of the Professional Code now allows, by default, practice "within an organization, whatever its legal form" — corporation, S.E.N.C.R.L. (limited liability partnership), S.E.N.C. (general partnership), cooperative, non-profit organization (OSBL). The full text of the new regulation appears in the Gazette officielle; the Ordre des CPA du Québec's page on practising within an organization confirms the replacement. A telling detail: in July 2026, the LégisQuébec codification still displayed the old text as "up to date as of April 1, 2026." Lastly, the regulation does not apply to a CPA working on their own account as a sole proprietorship.
The three regimes: who must be CPA-owned, and who isn't
The new regulation no longer sets a single rule, but three regimes depending on the services offered: certification organizations (section 3), those offering compilation engagements (section 4), and all other cases (section 5) — tax, advisory, bookkeeping — with no particular requirement on ownership or control.
| Situation | Ownership and control | Declaration to the Order | Excess insurance |
|---|---|---|---|
| Section 3 — certification services (audit, review) or an organization presenting itself as a CPA organization | "Effective control" exclusively by CPAs (from Quebec or another province) practising within the organization; more than 50% of the voting interests held by CPAs (or by organizations wholly owned by them); majority of directors who are CPAs (and of the quorum); at least one Quebec CPA voting holder; chair of the board = a CPA voting holder | Form + prescribed fees before starting + information return; annual update by March 31 | Yes: $1 million; $500,000 if the CPA practises alone, as the sole holder, with no other CPA employed |
| Section 4 — compilation engagements not intended exclusively for internal administration (no certification, not presenting itself as a CPA organization) | Exclusive effective control and more than 50% held by an expanded group: CPAs, members of a professional order, accountants from other provinces, real estate or mortgage brokers, insurance representatives, financial planners, securities brokers, actuaries; a majority of directors from among these persons; no requirement regarding the chair | Same as section 3 | Yes: same amounts |
| Section 5 — all other cases: tax, advisory, management, bookkeeping… without public accounting | No particular requirement — no ownership quota, no CPA directors | Declare the organization in your member file; information return only on request from the Order | May be required by the Order after a risk assessment |
Direct consequence: the myth of "more than 50% CPA-owned is mandatory" is dead for firms without public accounting. A CPA in tax or advisory can partner with a non-CPA, as long as the firm offers neither certification nor compilation for third parties and does not present itself as a CPA organization.
For a firm under regimes 3 or 4, the ownership and control conditions must be written into the articles of incorporation, with the stipulation that the organization is "incorporated primarily to offer professional services." Generic articles do not comply; uncorrected non-compliance results in a ban on practising within the organization. Plan for this at incorporation, not afterward.
What is reserved for CPAs? Public accounting — and nothing else
The Chartered Professional Accountants Act reserves only one activity for CPAs: public accounting — audit, review, attestations and special reports, and compilation engagements not intended exclusively for internal administration. Bookkeeping, payroll, tax returns, advisory and taxation are not reserved: anyone can offer them.
The non-CPA bookkeeper can incorporate freely
No professional order regulates bookkeeping: the incorporated bookkeeper follows the standard procedure, like any consultant who incorporates — no declaration to an order, no shareholding restriction, no mandatory insurance. And "accountant" on its own is not a reserved title — the Order itself states that being an accountant is not the same as being a CPA. Reserved to members only, on the other hand, are: CPA, chartered professional accountant, chartered accountant, CGA, CMA, public accountant, auditor, and any abbreviation that might suggest one of these.
The compilation trap
The line is crossed quickly: financial statements intended for the bank or an investor constitute a compilation engagement — a reserved act, the illegal practice of which exposes the non-CPA to criminal prosecution. Practical rule: exclusive internal use, yes; handed over to third parties, no.
What insurance does an incorporated CPA need? Two tiers not to confuse
The incorporated CPA carries two layers of coverage: the base coverage, mandatory for all CPAs, taken out through the Fonds d'assurance de l'Ordre (the Order's Insurance Fund) ($1 million per claim), and — for organizations under sections 3 and 4 — excess insurance taken out by the corporation with a private insurer, at your choice: $1 million, or $500,000 for the CPA who practises alone as the sole holder.
On the base side, the Fund's coverage reaches $2 million per claim for all insureds of the same organization; the premium in effect in 2026 is $1,750 for third-party services exceeding $9,999 per year. For section 5, the Order may require excess coverage after a risk assessment, but it is not automatic.
One principle remains: a CPA's personal liability for their own fault is never limited — the Code of Ethics prohibits it. The corporation protects against faults committed by other shareholders or partners and separates assets for other debts, without professional immunity.
What taxes apply to an incorporated accounting firm? 12.2%, 11.2% or 20.5%
An incorporated firm that accumulates at least 5,500 paid hours per fiscal year benefits from both small business deductions: about 12.2% combined (9% + 3.2%), and 11.2% for tax years beginning after April 29, 2026 (9% + 2.2%). A solo CPA with no employees does not reach the threshold: their corporation pays about 20.5% (9% + 11.5%).
This is the angle specific to accounting firms: with 3 or 4 full-time employees or more, the 5,500 hours are often reached. Solo, the advantage rests mainly on tax deferral — income left in the corporation is taxed at the corporate rate rather than at your marginal rate. If you withdraw everything every year, the net gain is thin: our guide When should you incorporate in Quebec? shows the calculation.
The 2026 context favours the CPA starting out: according to Le Quotidien (February 2025), citing the Order, the number of "CPAs in training" fell below 5,000 as of March 31, 2024 — down 9.1% over two years — and the Order published a white paper on the shortage in public accounting in May 2026.
How to incorporate as a CPA, step by step
Order matters: first the corporation with articles adapted to your regime, then registration, the declaration to the Order — before starting, for a firm under sections 3 or 4 —, insurance, and finally practice. Here are the steps to start a business adapted for the CPA.
Step 1 — Incorporate the corporation with the right articles
The corporation is incorporated with the Registrar (articles, share capital, initial declaration, NEQ) — 2026 government fees: $397. For a firm under sections 3 or 4, the articles must contain the regulation's conditions and the stipulation "incorporated primarily to offer professional services"; for section 5, standard articles are generally enough. This is the step covered by our $497 all-inclusive incorporation service, government fees included.
Step 2 — Registration, CAE code and the corporation's accounts
Registration with the Enterprise Register goes along with incorporation: this is where you declare your CAE code (7731, 7732 or 7739). Next come the corporation's bank account and, depending on your situation, registration for GST and QST — included in the Complete package at $697. Annual rights payable to the Registrar: $106.
Step 3 — Declare the organization to the Order
Certification or compilation firm (sections 3 and 4): form, prescribed fees (amount set by the Order) and information return, before starting operations. All other cases (section 5): declare the organization in your member file as soon as you begin offering services. In parallel, the Order requires training on the Code of Ethics (3 h + 1 h) and, if you have never practised in a firm or have been absent from practice for more than 5 years, a return-to-practice assessment. These steps are carried out directly with the Order, by the CPA personally.
Step 4 — Set up the two tiers of insurance
The Order's Insurance Fund is declared with your annual registration; the corporation's excess coverage (sections 3 and 4) is taken out with a private insurer — a condition for practising within the organization.
Step 5 — Practise, then maintain compliance
On a recurring basis: annual declaration and dues to the Order by March 15 ($935 for 2026–2027, before taxes and the contribution to the Office des professions); update of the organization form by March 31 (sections 3 and 4 only); notice without delay in the event of insurance cancellation, bankruptcy or dissolution; annual update with the Registrar; keeping the minute book.
Step 1, prepared and filed for $497 all-inclusive
Incorp-Québec prepares your articles and your initial declaration, files the file with the Registrar and pays the $397 government fees. The requirements specific to the Ordre des CPA — applicable regime, section 3 and 4 clauses, declaration, insurance — remain your professional responsibility.
Pitfalls to avoid
The most costly mistakes in 2026 come down to one sentence: relying on outdated content. Six documented pitfalls.
- Relying on the former regulation. Any source that cites the "practising through a corporation" regulation (C-48.1, r. 16) as current law has been out of date since April 16, 2026.
- The myth of "more than 50% CPA-owned is mandatory." A firm without public accounting that does not present itself as a CPA organization has no ownership requirement: that only applies to sections 3 and 4.
- The compilation trap for bookkeepers. Financial statements intended for the bank = compilation engagement = reserved act. Exclusive internal use only, for the non-CPA.
- The 12.2% myth. A solo CPA without 5,500 paid hours pays about 20.5%. See the real cost of incorporation before deciding.
- Generic articles for a section 3 or 4 firm. Without the required clauses, the practice is non-compliant — fix this at incorporation.
- Looking for excess insurance through the Order. The base coverage comes from the Order's Fund; the corporation's excess coverage is taken out privately, with the insurer of your choice.
FAQ — Incorporation for a CPA accountant in Quebec
Can a CPA incorporate in Quebec in 2026?
Yes. Since April 16, 2026, the Regulation respecting the practice of the chartered professional accountant profession within an organization (Decision OPQ 2026-991, Gazette officielle of April 1, 2026) allows practice through a corporation, an S.E.N.C.R.L., an S.E.N.C., a cooperative or a non-profit organization, under three regimes that depend on the services offered.
Do you have to declare the corporation to the Order before starting?
Yes. A certification or compilation firm (sections 3 and 4) sends the Order the form, the prescribed fees and an information return before starting its activities. In all other cases (section 5), the CPA declares the organization in their member file as soon as they begin offering services.
Does my corporation have to be majority-owned by CPAs?
Only if it offers certification or presents itself as a CPA organization (effective control exclusively by CPAs, more than 50% of the votes, a majority of CPA directors, a CPA chair), or compilation engagements (more than 50% held by an expanded group of professionals). Otherwise — tax, advisory, bookkeeping — there is no particular ownership requirement.
What insurance is mandatory for an incorporated CPA?
Two tiers: the base coverage from the Order's Insurance Fund ($1 million per claim; a premium of $1,750 in effect in 2026 for third-party services exceeding $9,999 per year), then, for organizations under sections 3 and 4, excess insurance taken out by the corporation privately: $1 million, or $500,000 for the CPA who practises alone as the sole holder.
Can a non-CPA offer bookkeeping and tax return services?
Yes. Only "public accounting" — audit, review, attestations and compilations intended for third parties — is reserved for CPAs under the Chartered Professional Accountants Act. Bookkeeping and tax returns are not: a non-CPA bookkeeper can incorporate freely, with no declaration to an order.
Is "accountant" a reserved title in Quebec?
No. The Order itself states that being an accountant is not the same as being a CPA. Reserved titles are: CPA, chartered professional accountant, chartered accountant, CGA, CMA, public accountant and auditor, along with any abbreviation that might suggest one of these.
Can a bookkeeper prepare financial statements?
Only for purposes exclusively related to internal administration. As soon as they are intended for a third party — a bank, an investor —, it becomes a compilation engagement, a public accounting act reserved for CPAs, the illegal practice of which exposes one to criminal prosecution.
What taxes does an incorporated accounting firm pay?
About 12.2% with both small business deductions (11.2% for years beginning after April 29, 2026) — but Quebec's 5,500 paid-hours criterion generally excludes the solo CPA, whose corporation pays about 20.5%. A firm with a few full-time employees often reaches the threshold.
Ready to incorporate your firm?
Your corporation set up for $497, government fees included
A form of about 20 minutes, documents prepared and verified, filed directly with the Registrar of Enterprises. The requirements of the Ordre des CPA — applicable regime, declaration, insurance, training — remain your professional responsibility.
Incorp-Québec is a document preparation service for incorporation: we prepare and file your incorporation file. Steps with the Ordre des CPA du Québec (organization declaration, training, insurance) are carried out by the client. The clauses in your articles must be validated according to your regime (sections 3, 4 or 5) before practising within the organization.