Published 12 September 2026 · By Jatin Dua, Broker of Record, RE/MAX Quantum Realty
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Get My Free Estimate →CPA Ontario is not the constraint on your premises. I could find no CPA Ontario requirement specifying what the physical office must contain. What the regulator cares about is the address and the office as a unit: Regulation 10-1 provides that “a reference to the registration of a Firm means the registration of each office of the Firm” through which a member practises public accounting or provides accounting services to the public. Everything that actually decides whether a space works — zoning, change of use, capacity at peak, HVAC hours — comes from the City, the building and the lease.
The regulator registers your office, it does not design it
There is no minimum size, no required room, no prescribed layout and no pre-occupancy premises approval in CPA Ontario’s published regulations. I looked for one. What there is instead is registration, and registration is per office.
That distinction matters more than it sounds. If you are opening a second location, or consolidating two into one, you are not only signing or surrendering a lease. You are changing the information in your firm registration, and Regulation 10-1 provides that changes to that information must be disclosed to the Registrar within 30 days and “shall be subject to the Registrar’s approval.” So the lease decision and the registration decision are the same decision, taken in a particular order.
| Question about the premises | Who decides it |
|---|---|
| Size, layout, required rooms | Nobody. No CPA Ontario specification exists. |
| Registering the office and its business address | CPA Ontario, per office, under Regulation 10-1 |
| Where a practice inspection happens | The Practice Inspector: the office, another location, or by document submission |
| Whether an accounting office is a permitted use at the address | City of Toronto, under Zoning By-law 569-2013 or a former municipal by-law |
| Whether a change-of-use permit is required | The chief building official, under the Building Code Act |
| Whether you can staff the space at peak and pay for it at trough | The lease: term, expansion rights, HVAC hours, parking |
An inspection can happen at your office
Regulation 18-1 provides that an inspection “may take place at the office of the Practising Unit or other location as deemed appropriate, or by submission of documentation by the Practising Unit to the Practice Inspector.” A practising unit is defined by reference to the work done “in a particular office, or an aggregate of offices,” as determined by CPA Ontario’s VP, Public Accounting and Practice Inspection.
Two consequences. First, the office is a unit of regulation, not just a cost centre, so how you group locations is a question to ask before you sign a second lease rather than after. Second, your premises may host a regulator. A practice profile questionnaire has to be returned within 60 days of the request and the working papers behind it have to be findable. A space with nowhere to sit an inspector makes an ordinary process harder than it needs to be.
Records: no fixed period, some of it indefinite, and all of it has to live somewhere
The CPA Code of Professional Conduct sets no retention period. Rule 218 requires a member or firm to retain, “for a reasonable period of time,” working papers, records and other documentation that reasonably evidence the nature and extent of the work done. The guidance admits “it is not possible to give an all-encompassing guideline as to what is reasonable,” and says that “at a minimum, documentation should not be destroyed until legal advice has been obtained with respect to any limitation periods that may apply.”
Then the sentence with a floor-area consequence. While a general guideline “might be as short a period as the minimum time period required by statute, some documentation may need to be retained indefinitely,” and the guidance lists financial statements, agreements, contracts and leases, minutes, investment and share capital information, written opinions, tax files and assessment notices, continuity schedules, and estate plans and wills.
The same guidance directs that client information be segregated from the firm’s own proprietary information, and that where the firm holds a client’s books and records, those be maintained separately. That is a storage instruction as much as a filing one. Rule 212 adds that trust funds and the property of others are “to be separated from the member’s or firm’s assets and used only for the purpose for which they are intended.”
So: a lockable file room you control, sized for material you are not free to destroy, plus enough separation that client property is never mixed with the firm’s. Ask about that room on the first viewing, not the third.
The problem no other office tenant has: you are sized for the busy season
This is the genuinely unusual thing about accounting premises, and the one I spend the most time on. An accounting firm’s headcount is not flat. Through the filing season it runs at maximum: permanent staff, seasonal and contract staff, students, longer hours, and clients coming in with paper. For the rest of the year the same floor area sits at a fraction of that. You sign a lease for the peak and pay for it every month.
I will not give you a ratio, because no primary source publishes one and the shape of it differs from firm to firm. What I can do is tell you which lease terms the seasonality actually lands on.
Term and flexibility. If your peak requirement is growing, a right of first offer on adjacent space is worth more than a lower face rent. If it is shrinking because more of the work is remote, a shorter term with a renewal option beats a long term at a discount.
Desks you do not assign. Seasonal staff do not need permanent workstations. They need somewhere to sit, a lockable place for files, and network access. That is a fit-out and furniture decision with a real rent consequence, and it is easier to make before you choose the unit.
Reception and meeting rooms. Client drop-ins cluster in the same weeks. A reception area sized for a quiet week does not work in the busiest one, and meeting rooms that sit idle for months are then contended for daily.
Security with more people in the building. Temporary staff, longer hours and more paper moving around is exactly when the segregation of client records from firm information matters most. Access control on the file room is cheap at fit-out and awkward to retrofit.
An accounting firm works nights and weekends when everyone else’s building is dark. Find out, before you sign, exactly what your lease says the building’s normal operating hours are, and exactly what happens outside them: whether heating, cooling and lighting are billed separately, at what rate, how that rate can change during the term, whether after-hours access is by card and at what cost, and whether the elevators actually run at weekends. If you do not settle those in the lease, you will find out in your first filing season, on an invoice, after the work is already done.
Zoning: office use is common, not automatic
Toronto’s Zoning By-law 569-2013 is city-wide, but it is not the whole story. The City says some properties remain subject to former municipal by-laws, and that some provisions of 569-2013 are under appeal to the Ontario Land Tribunal and “are not in full force and effect.” Site-specific exceptions in Chapter 900 can override the base zone, and the defined meaning of a use term in Chapter 800 controls, not the ordinary meaning.
The City’s four steps: find the property and its zoning category on the interactive map; review permitted uses and conditions in the zone; check Chapter 900 for site-specific exceptions; review the city-wide and use-specific regulations. Permissions are layered within each zone, some uses permitted outright and others only on stated conditions. In the Commercial Local zone, the uses permitted without conditions include office and financial institution. Common. Not universal.
Two formal City reviews exist, both non-refundable, fees effective 1 January 2026. A Zoning Use Review assesses “whether the following uses are permitted for a specific location, under the current applicable Zoning By-law,” requires no plans, and costs $214.79 per registered lot. A Zoning Applicable Law Certificate is the detailed pre-permit review “to determine zoning compliance and confirm compliance with other applicable law,” at $214.79 for other proposals, $888.14 for small buildings up to 300 m² and $1,863.82 for larger ones. Note that the former Zoning Certificate and Preliminary Project Review services have been discontinued and replaced by the Zoning Applicable Law Certificate, so older checklists are out of date. The offer mechanics are in my piece on the zoning condition.
Change of use: assume a permit until the City says otherwise
The Building Code Act provides that “even though no construction is proposed, no person shall change the use of a building or part of a building or permit the use to be changed if the change would result in an increase in hazard, as determined in accordance with the building code, unless a permit has been issued by the chief building official.” The chief building official must issue the permit unless the proposed use would contravene the Act, the building code “or any other applicable law,” the application is incomplete, or fees are unpaid. That phrase, “any other applicable law,” is what makes zoning compliance a condition of the permit.
The City of Toronto states it without the qualifier: a permit is required to “change a building’s use (i.e. from residential to office…),” and “even if no construction is proposed, if a change of use is proposed a building permit is required.” It also warns that “even if a building permit is not required, compliance with the Zoning Bylaw is required.” Inside Toronto, treat the City’s version as the operating rule and confirm with the chief building official. The current Code is O. Reg. 163/24, amended repeatedly through 2025 and 2026, so make sure anyone quoting a Code provision is quoting the current one.
The short version
CPA Ontario does not specify your premises. It registers each office and it can inspect at that office, and changes to your registration information need the Registrar’s approval. Records have no fixed retention period and some categories may need to be kept indefinitely, so budget secure, controlled storage. Then spend your attention where the money is: confirm zoning in writing, assume a change-of-use permit, and negotiate the lease around a headcount that peaks for a few months and is paid for twelve. Building hours and the after-hours HVAC rate are not boilerplate for an accounting firm. They are a core economic term.
Meeting rooms, sightlines and the confidentiality that has no dimensions
Nothing in CPA Ontario’s regulations tells you how many meeting rooms to build or how thick a wall to specify. The duty to keep client information segregated and secure does not come with measurements. But it is the reason an accounting office cannot be an open room with a printer in the corner.
The questions worth asking on a viewing are about separation, not finishes. Does the demising wall run to the deck or stop at the ceiling grid? Does the return air path connect your meeting room to the tenant next door? Can someone at reception read a screen on the nearest desk? Is there one room where a difficult conversation about a CRA assessment can happen without an audience?
Every fix is an alteration, and alterations run through the landlord: the alterations clause, the consent, the landlord’s contractor if the lease requires it, and the restoration obligation at the end of term, which quietly decides what the build-out really costs. Settle that language before you commit to a floor plan. More in my piece on the lease clauses that decide the economics.
Accessibility: what AODA reaches
The Integrated Accessibility Standards Regulation attaches obligations to the organization by size.
| Employees | What is required |
|---|---|
| 1 to 19 | Accessibility policies (documentation optional), training, accessible customer service and employment practices, accessible information on request, kiosk planning, accessible public spaces on new construction and renovation. No compliance report. |
| 20 to 49 | All of the above, plus an accessibility compliance report every three years. |
| 50 or more | All of the above, plus documented policies, a multi-year plan reviewed every five years and posted online, written training records, documented accommodation processes, and accessible public websites. |
Count carefully if you staff up seasonally, because the thresholds are employee counts and the obligations differ across them. The next compliance reporting deadline for organizations with 20 or more employees is December 31, 2026, and the province warns that failure to report “could face enforcement measures which can include financial penalties.”
On the physical side, the Design of Public Spaces standard applies to public spaces that are newly constructed or “redeveloped,” and “redeveloped” is defined as “planned significant alterations to public spaces, but does not include maintenance activities, environmental mitigation or environmental restoration.” Large organizations have been in scope since 1 January 2017 and small organizations since 1 January 2018. It covers exterior paths of travel, accessible off-street parking, outdoor eating areas, and obtaining services, including service counters. The counter rule bites “when constructing new service counters, which includes replacing existing service counters,” so a new reception desk is a trigger, and the replacement has to accommodate a mobility aid with a usable countertop height, knee clearance where a forward approach is needed and clear floor space in front. The standard does not govern the inside of your suite; barrier-free requirements for building interiors sit in the Ontario Building Code, which is a question for your designer and the chief building official.
Parking, at the worst possible time of year
Parking is not a professional requirement. It is a client and staffing requirement, and for an accounting firm it fails exactly when it matters most: peak season puts more staff cars and more client visits in the same lot on the same days.
Ask how many stalls are reserved rather than shared, whether visitor parking is landlord-controlled or run by a third-party operator, what the monthly rate is and whether it can rise during the term, whether seasonal staff can be added to the allocation and on what terms, and what enforcement looks like when the lot is full. The IASR’s accessible off-street parking requirements apply where a parking area is newly constructed or redeveloped. Everything else is the lease. That is a parking clause question and it belongs in the offer.
What belongs in the lease review condition
Give your lawyer time to read and yourself time to get City confirmation, and make sure the review covers at least these.
Permitted use. Does it name an accounting office, or something narrower you will have to justify later?
Hours, HVAC and after-hours charges. The seasonal term: hours, rate, escalation, access.
Expansion, contraction and rights of first offer. Your headcount is not flat. Your lease should not assume it is.
Alterations and restoration. What you may build, whose contractor, what comes out at the end.
Assignment. The Commercial Tenancies Act deems a covenant against assigning without consent to be subject to a proviso that consent “is not to be unreasonably withheld,” but only “unless the lease contains an express provision to the contrary.” A lease can validly give the landlord absolute discretion. Where consent is unreasonably withheld, a judge of the Superior Court may make an order that operates as the landlord’s consent. And a consent extends “only to the permission actually given,” so it does not waive the covenant for the next assignment. If you ever plan to sell this practice, that clause is part of the sale.
I read the lease before the offer goes out. It is cheaper to lose a week at the front than to find out in your second filing season that the after-hours rate is whatever the landlord says it is. More in my piece on the lease review condition.
Does CPA Ontario have requirements for my physical office?
I could find no CPA Ontario requirement specifying the premises. What is required is registration of each office and the information that goes with it. Regulation 10-1 provides that “a reference to the registration of a Firm means the registration of each office of the Firm” through which a member practises public accounting or provides accounting services to the public, and registration requires the firm’s name, business address, telephone number and website, plus a designated Firm Representative with a business address and a valid email.
If I open a second location, is that just a second lease?
No. Registration under Regulation 10-1 is per office, so a second location is a second registered office. Changes to the information in your firm registration must be disclosed to the Registrar within 30 days, and Regulation 10-1 provides that those changes “shall be subject to the Registrar’s approval.” Practice inspection also works at the level of a practising unit, defined by reference to work done “in a particular office, or an aggregate of offices,” as determined by CPA Ontario. Ask before you sign.
Where does a practice inspection take place?
Regulation 18-1 says an inspection “may take place at the office of the Practising Unit or other location as deemed appropriate, or by submission of documentation by the Practising Unit to the Practice Inspector.” So it may or may not be at your premises. Either way, a practice profile questionnaire must be completed and submitted within 60 days of the request, and the working papers behind it have to be retrievable, which is a storage and filing question as much as an accounting one.
How long do I have to keep client records, and how much space is that?
There is no fixed period. Rule 218 requires retention “for a reasonable period of time,” and the guidance concedes no all-encompassing guideline is possible, directing that nothing be destroyed until legal advice on limitation periods is obtained. It adds that “some documentation may need to be retained indefinitely,” listing financial statements, agreements, contracts and leases, minutes, investment and share capital information, written opinions, tax files and assessment notices, continuity schedules, and estate plans and wills. Size the storage for that, not for last year’s paper.
How do I lease for a headcount that peaks for a few months?
No source publishes a peak-to-average ratio, so anyone quoting you one is guessing. What you can do is put the flexibility in the lease: a right of first offer on adjacent space if you are growing, a shorter term with renewal options if you are not, unassigned desks and secure lockers for seasonal staff rather than permanent workstations, and reception and meeting room capacity sized for the busy weeks rather than the quiet ones.
Is office use automatically permitted in a Toronto commercial unit?
No. Permissions are zone by zone. Office is among the uses permitted without conditions in the Commercial Local zone, but other zones differ, some properties remain under former municipal by-laws, Chapter 900 site-specific exceptions can override the base zone, and the City warns that some provisions of 569-2013 are under appeal and not in full force and effect. Get a Zoning Use Review at $214.79 per registered lot, or a Zoning Applicable Law Certificate if a permit is coming.
Do I need a building permit to convert a retail unit to an office?
Assume yes and confirm. The Building Code Act requires a permit for a change of use, even with no construction, where the change would increase hazard as determined under the building code. The City of Toronto states the requirement without that qualifier: if a change of use is proposed, a building permit is required. The City also warns that even where no permit is needed, zoning compliance still is. Confirm with the chief building official before you commit to the space.
What are after-hours HVAC charges and why do they matter here?
Leases commonly define the building’s normal operating hours and treat heating, cooling and sometimes lighting outside those hours as a separately billed service, but the terms vary building to building, so read yours. An accounting firm works well outside normal hours when the season demands it, which turns that rate into a recurring operating cost rather than an occasional one. Ask for the hours, the rate, how it can change during the term, and whether after-hours access and elevators run at weekends. Then put the answers in the lease.
Sources
- CPA Ontario — Regulation 10-1 (Firms)
- CPA Ontario — Regulation 18-1 (Practice Inspection)
- CPA Ontario — Member’s Handbook, including the CPA Code of Professional Conduct
- City of Toronto — Zoning By-law 569-2013
- City of Toronto — Zoning By-law Chapter 30.20, Commercial Local Zone (CL)
- City of Toronto — When Do I Need a Building Permit?
- Government of Ontario — Accessibility rules for businesses and non-profits
- Ontario e-Laws — Commercial Tenancies Act, R.S.O. 1990, c. L.7
LOOKING AT ACCOUNTING OFFICE SPACE IN THE GTA?
Send me the address and the draft lease before you sign. I will tell you what the zoning question actually is at that property, what the building’s hours and after-hours charges will cost you in a filing season, whether there is room to expand when you need it, and whether the storage on offer matches the records you are not allowed to destroy. Etobicoke, the west end and the wider GTA.
Book a 15-minute call or call or text 833-330-1925.
I will not tell you how many square feet per person you need. No credible source publishes it, and the honest answer depends on how your busiest weeks actually run.
More in this series
Jatin Dua is Broker of Record and co-founder of RE/MAX Quantum Realty, Brokerage, Unit 101, 799 The Queensway, Etobicoke. Four-plus years in the GTA and more than $100M in sales volume. He works on commercial and business purchases across Toronto and the west GTA.
This is general professional commentary from a Broker of Record on commercial and business acquisitions in Ontario. It is not legal, tax or accounting advice, and it does not create any professional relationship. Whether a licence transfers, how a purchase should be structured, what tax applies and what a regulator will require on your particular file are questions for your lawyer, your accountant and the regulator itself. Rules, fees and published requirements change — verify anything you intend to rely on against the primary source on the day you rely on it.