A commitment to consciously upholding professional ethics defines the very essence of a chartered accountant’s mandate. Consequently, CA ANZ’s annual subscription renewal process includes the requirement that members make a mandatory declaration regarding their compliance with membership obligations.

Kate Dixon and Rebecca Stickney, leaders of the CA ANZ professional conduct teams in Australia and New Zealand respectively, discuss the significance of the declarations, how they are monitored and how the disciplinary bodies deal with disclosures.

When renewing their subscription, members must respond to a range of questions relating to areas of practice, character or fitness requirements, continuing professional development (if applicable), as well as whether they have been subject of a notification or disclosure event in the previous year.

The declaration must be made by all CA ANZ members. Particular types of members, including auditors and licensed audit firms in New Zealand, have additional reporting obligations.

Fitness to practice declarations

Dixon says the six questions regarding fitness to practice correlate to notification and disclosure events, which members are required to notify the Professional Conduct Committee (PCC) of, under the CA ANZ by-laws and New Zealand Institute of Chartered Accountants (NZICA) rules. The questions asked in the declaration are:

Have you...

1. Been charged with, pleaded guilty to or been convicted of any criminal offence, tax offence or other offence?
2. Been subject to any disciplinary action or any binding adverse findings by a court, tribunal, regulator, professional body or other organisation relating to your integrity or honesty, or business conduct generally?
3. Personally experienced an insolvency event, such as bankruptcy?
4. Been refused a registration or licence in a professional capacity, had one cancelled or suspended, or had a condition imposed?
5. Been a principal of a practice entity that has experienced any of the above?
6. Anything else to declare that could affect your fit and proper standing under the CA ANZ by-laws, NZICA rules or any relevant legislation?

If members are unsure whether a matter needs to be disclosed, they should refer to the definitions of ‘disclosure event’ and ‘notification event’ in the by-laws and rules.

Stickney urges members not to hold back, there is no reason to be afraid of disclosing information.

“Not all declarations result in a complaint or any action, but members should err on the side of caution and disclose relevant information. It’s what a responsible professional does.”

Stickney says the PCC occasionally sees cases where members have failed to disclose relevant matters in their annual declaration or have provided misleading information, “and these are considered aggravating factors by the disciplinary bodies, and can increase the sanction imposed”.

Conversely, she says, “Proactively disclosing a matter is viewed favourably by the disciplinary bodies in the event that the matter is serious enough to warrant disciplinary action.”

Stickney says insolvency is another area that members need to proactively disclose. “That includes not only active states of insolvency such as bankruptcy, liquidation and receivership for practice entities, but can extend to the inability to pay creditors as they fall due.”

In addition to this annual declaration, Dixon reminds members of their ongoing obligation, as required by the by-laws and rules, to report notification and disclosure events to the PCC in writing within seven days of becoming aware of them, and to submit reports to the correct email address.

“Such events include convictions, insolvency events, the conviction for tax and other offences, adverse or unfavourable findings or undertakings imposed by the courts or other bodies or regulators, and other matters which could be a breach of the by-laws or rules.”

Failure to disclose can have serious repercussions

Dixon recalls a case where a member failed to advise an adverse finding by another professional body in relation to their professional conduct, competency and integrity.

“He wasn’t open and timely in his dealings with the PCC,” she says. “The tribunal highlighted the need for members to comply with their obligations under the by-laws by appropriately notifying and advising relevant matters.

“Failure to disclose this information was one of the reasons why he was suspended from membership for three years.”

The disciplinary tribunal also required the member to pay costs of A$16,000.

Misleading disclosures are also problematic

Stickney says there have been a number of cases involving misleading declarations, where members have actively declared they did not offer accounting services to the public or undertake assurance engagements, when that was not the case. Some cases have also involved repeated misleading declarations regarding compliance with continuing professional development (CPD) obligations.

“Where the disciplinary bodies have found misleading or false declarations have been made, serious disciplinary outcomes usually follow because of the breach of the fundamental principle of integrity. Censures or reprimands are usually issued, along with fines of between A$5000 to A$10,000 on top of the costs of the proceedings, as well as publication of the member’s name.”

What happens when you make a disclosure?

The PCC will review all disclosures made and decide whether or not a complaint should be opened. More questions may need to be asked before an assessment can be made. If a complaint is opened, the member will be given the opportunity to provide additional information about the matter, which is considered by the PCC.

Self-disclosure of potential issues with your fitness to practice, including the requirement to complete the mandatory declarations, is an important part of the protection by CA ANZ and NZICA of the reputation of the profession. It ensures the PCC has all the information it needs to consider the professional conduct of our members and assists in protecting the public interest.

Take away

CA ANZ’s first Quarterly Ethics Digest will reach your inbox on 1 October 2025, with the latest ethics-related content and resources for members.

Previous articles from Acuity magazine on this subject are: The Mea Culpa Effect and Wrong Doing Has a Long Reach.

How to self-report

Members in Australia and rest of world

Log in to My CA, and download and complete the Disclosure and Notification Form. Email the form to: [email protected]

Members in New Zealand

Email: [email protected]

Please include:

• Member details
• An explanation of the event and when event occurred
• Copies of any relevant supporting documentation.