Thank you for your question.
As I mentioned, there are actually three requirements to be met by public accountants in order for them to practise or give their opinion on the financial statements of an organization under this Act. The first one is to be a member in good standing of an institute or association of accountants. The second one is somewhat problematic since it has a second provision whereby a public accountant must also comply with provincial enactments.
Recently, the provincial premiers all came to an agreement and thus struck a major blow for the improvement of Chapter 7, respecting the mobility of workers in Canada. It was concluded once again that it is really the principle of mutual recognition that should determine the mobility of workers in Canada. This principle provides that, if a professional's qualifications are recognized in one province, they must also be recognized in another province, full stop. According to our interpretation, the section in question brings another factor into play. Even if they are qualified, public accountants must meet another criterion that has not been specified in the Act. It is a little too vague.
Really, under subsection 181(1), public accountants must be members in good standing of an institute or association of accountants, and that's that. That's enough. It is the body that must ensure that they are qualified and able to do the job. If they're not, it's up to the body to take the disciplinary action required.