Under the RCIC client account rules in section 32 of the CICC Code of Professional Conduct, an advance payment must be held in trust in a client account at a College-approved financial institution, receipted, recorded separately for each client and used only for its purpose. You may invoice only after providing services, and when the file ends you must account for the funds and refund any excess within 30 days.
- Advance payments go into a client account at a College-approved financial institution, held in trust.
- Receipt every payment and keep separate deposit and withdrawal records for each client.
- Invoice only after services are provided; charging above the estimate needs the client’s written agreement.
- Within 30 days of closing, account for all funds and refund any excess held in trust.
- Report an error in trust funds to the Registrar within 30 days.
Money is where small process gaps turn into regulatory problems. This guide sets out what the CICC Code says about client funds and turns it into an office routine. The rules quoted come from the Code of Professional Conduct (SOR/2022-128) on Justice Laws, checked 3 November 2026. The College may publish further guidance on approved institutions and record-keeping, so check its current material as well.
What do the RCIC client account rules require?
Section 32 of the Code applies when a client pays you in advance. The licensee must:
- hold the funds in trust in a client account, opened by the licensee, at a financial institution approved by the College (s. 32(a));
- give the client a receipt that clearly shows the amount of the advance payment (s. 32(b));
- not deposit funds that do not belong to a client into the client account (s. 32(c));
- keep separate records of deposits and withdrawals for each client (s. 32(d));
- use the funds only for the purpose for which they were paid (s. 32(e)); and
- deal with invoiced amounts within the time the Code sets — section 32(g) refers to a period of 30 days after the day the client is invoiced.
When can you invoice and move money out of the client account?
The Code says a licensee may invoice a client only once they have provided immigration or citizenship consulting services (s. 33(1)), and must give a receipt for each payment received (s. 33(3)). Fees must be fair and reasonable, disbursements must not exceed actual cost, and charging more than the estimate in the service agreement needs the client’s written agreement (s. 31).
In practice, that means tying each invoice to a stage of work that has been done — for example “file assessment completed” or “application submitted” — rather than to a calendar date.
What happens to client funds when the file closes?
Within 30 days after the services are completed or the service agreement is terminated, section 36(1) requires the licensee to, among other things, return the client’s documents, provide an accounting of all funds received from the client, and refund any funds held in trust on the client’s behalf beyond what has been invoiced.
If you discover that an error was made in the use or attribution of funds held in trust in a client account, section 39(f) requires you to report it to the Registrar within 30 days. Section 42(2)(a) also requires reporting another licensee who misappropriates or misapplies client funds.
A simple monthly routine for client funds
- At signing. Put the fee estimate, payment terms and refund policy in the service agreement, as section 24(3) of the Code requires.
- On every payment. Decide whether it is an advance (client account) or payment of an issued invoice, issue a receipt the same day and record it against the client.
- At each milestone. Invoice only for work done and move the invoiced amount as the Code requires.
- Monthly. Compare the client-account bank balance with the total of your per-client records; investigate any difference immediately.
- At closing. Prepare the accounting of funds and any refund within 30 days, and keep the record with the client file.
Related reading: how to manage retainer agreements, RCIC confidentiality and file-keeping duties, and the comparison of immigration software with card and eCheck payments.
General information about running an immigration practice — not legal advice. Rules change; confirm current requirements with official sources and your regulator.