Date posted: 06/12/2023 8 min read

Public interest: ethical dilemmas

Many complaints are received by the Professional Conduct Committee every year but there are four recurring themes to be aware of. And, if a chartered accountant is facing any ethical dilemmas, counselling and support is available from the CA Advisory Group.

Quick take

  • 2023 complaint statistics: 421 complaints received, 140 of which were resolved without investigation.
  • “It’s not necessarily the underlying work that has been done badly, but members might not be communicating adequately with clients,” says Rebecca Stickney, CA ANZ
  • The CA Advisory Group provides counselling and support for CAs facing ethical dilemmas or weighing career decisions.

CA ANZ received about 420 complaints over the 2022–2023 financial year, and while many of them were dismissed by the Professional Conduct Committee (PCC), they highlight some recurring issues. Kate Dixon and Rebecca Stickney, leaders of the CA ANZ professional conduct teams in Australia and New Zealand, discuss four common themes raised by these complaints and how members might avoid being subject to one.

1. Due care and diligence

Dixon says this is the area where most complaints have arisen over the last year, and includes allegations that work has not been done on a timely basis, with appropriate care, or where there has been poor or inadequate communication with clients, or inadequate terms of engagement.

“We have seen an increase in these kinds of issues in the past few years, and this trend is persisting,” she says.

Stickney agrees that some members are struggling with work expectations. “It’s not necessarily the underlying work that has been done badly, but members might not be communicating adequately with clients.

“Some members are experiencing high workload pressures, partly due to staff shortages and the lasting impacts of COVID. Managing clients’ expectations is important.”

She says it is also vital that members are clear with clients about cost increases, as this is a constant theme in complaints. “Even though this might require some challenging conversations, you just have to be upfront and communicate any changes.”

While the PCC doesn’t investigate fee disputes, unless there is an ethical component to the complaint, there is an expectation that members provide appropriate disclosure to their clients about fees.

2. Unprofessional behaviour

Some members come to the attention of the PCC due to allegations of unprofessional behaviour, which includes being discourteous to clients or failing to comply with professional clearance expectations.

“All professional communications, including those between a former accountant and the new accountant, are required to be professional, courteous and timely,” says Dixon.

“Members need to adequately communicate whether there are any reasons why the new accountant shouldn’t take on the client and to pass over any client records, unless there’s an appropriate basis for asserting a lien.”

Stickney says she has seen cases where members are annoyed about clients moving to a new accountant and therefore not responding appropriately to the new accountant’s enquiries, “or they are ignoring it altogether or asserting liens when they don’t have justification for doing so”.

Members should also ensure that they respond to any queries but that their responses do not contravene their obligations of confidentiality.

“It’s not necessarily the underlying work that has been done badly, but members might not be communicating adequately with clients.”
Rebecca Stickney, CA ANZ

3. Failure to comply with CA ANZ/NZICA requirements

Each year, complaints are raised against members who have failed to comply with CA ANZ or NZICA compliance requirements. This may include practising as a public accountant without a certificate of public practice (CPP), failure to have a quality and practice review and, in Australia, failure to comply with the obligation to complete the Professional Standards Scheme questionnaire. The PCC takes such matters seriously and expects members to comply with these requirements. If members delay, it is taken into account by the PCC in considering the appropriate sanction to apply to the member.

4. Integrity

The PCC takes all alleged breaches of integrity very seriously. There are many different types of complaints which raise integrity issues, including creating or lodging false or misleading documents, dishonesty, allegations of misappropriation of client funds and a failure to act with integrity in academic matters. The PCC ensures that appropriate evidence is sought to substantiate the allegations and investigates these matters in depth. If an integrity breach is substantiated, the consequences for the member may be severe, including having their membership terminated, suspended, or suspended on an interim basis pending finalisation of the investigation.

On the other hand, Stickney says complaints are also received that are not supported by adequate evidence or that don’t stack up.

“For example, we might receive a complaint from a member of the public claiming their accountant is being dishonest by preparing false documents, however when you unpack the actual complaint, this may simply be a misunderstanding. If this is the case, then it is likely that an integrity breach will not be sustained.”

Safeguard yourself against complaints

Stickney says it’s important members who are feeling overwhelmed seek help.

“If you’re feeling burnt out and are struggling to meet your workload or deal with a particular client, reach out to someone who can help. If you’re in business with other people or have staff, share the burden with people who understand the issues.

“Sometimes members find it hard to either delegate or to tell people that they’re having a tough time. We’ve seen some cases where people have buried their heads in the sand and created a much bigger problem out of something that could have been quite easily resolved.”

She says members who are sole practitioners can reach out to their peers and colleagues, and CA ANZ has various avenues of support available.

“We want people to succeed and to feel supported.”

2023 complaint statistics

  • 421 complaints received, 140 of which were resolved without investigation
  • 221 complaints resolved at PCC level
  • 26 were determined by the Disciplinary Tribunal
  • 24 were withdrawn
  • 5 were determined on appeal
  • 14 members had their membership terminated or suspended.


  • 65% of the complaints were CPP holders, or those in public practice
  • 35% of the complaints were directed at non-CPP holders, including practice entity members and those in the corporate and non-profit sectors, or staff of public practitioners who don’t hold a CPP.


  • 60% of complaints came from the public
  • 9% were self-reported
  • 14% of the complaints arose from CA ANZ, NZICA or the PCC
  • 17% of complaints came from other sources.

Need help?

The CA Advisory Group provides counselling and support for chartered accountants facing ethical dilemmas or weighing career decisions. Local panels of experienced CAs offer guidance for fellow members and can provide you with advice and support on a range of professional and ethical matters.

The CA Advisory Group service is free and all discussions are strictly confidential

Visit: CA advisory group website to find the 19/10/21 resource.
Call: 1300 137 322 (Australia) or 0800 469 422 (New Zealand).