One question I am frequently asked by my fellow colleagues (specially the beginners) is:
“Can I provide additional services such as translation, tax preparation, air ticketing, accommodation booking, or other non-immigration services to my immigration clients if I am legally authorized and operate those lines of business?”
Based on my reading of the CICC Code of Professional Conduct, there is no provision that expressly prohibits or expressly permits an RCIC from offering other legitimate services to an immigration client, provided the RCIC is legally authorized to provide those services. Since the Code is silent on many of these services, RCICs should be guided by the broader principles of the Code, particularly those relating to conflicts of interest.
Examples of additional services that an RCIC may also be qualified or licensed to provide include, but are not limited to:
- Certified translation or interpretation services
- Income tax preparation and filing
- Air ticketing and travel arrangements
- Hotel or accommodation booking
- Settlement or relocation assistance
- Airport pickup arrangements
- Resume writing and interview coaching
- Language training or exam preparation (IELTS, CELPIP, PTE, TEF, etc.)
- Educational counselling (where otherwise permitted)
- Notary or commissioner services (where authorized)
- Business incorporation or business registration assistance (where legally permitted)
- Insurance or financial services (where separately licensed)
Whether these services are closely related to immigration or are entirely separate, the key consideration is ensuring that the client’s interests always come first and that no conflict of interest arises.
Although the Code does not specifically address services such as those listed above, I believe the guiding principles can reasonably be drawn from the conflict of interest provisions relating to employment recruitment services (sections 17(2)-(3)) and student recruitment services (sections 18(2)-(3)).
In my view, if RCICs apply the same principles to any additional service they offer, they can significantly reduce the risk of creating a conflict of interest.
At a minimum, I recommend that you:
- Clearly advise the client that they are under no obligation to obtain both immigration and non-immigration services from the same individual.
- Clearly distinguish the immigration consulting services from the other services in the service agreement.
- Fully disclose any commissions, referral fees, rebates, or other compensation received from third parties in relation to those additional services.
- Ensure compliance with all legislation, licensing requirements, and professional obligations governing the additional services being provided.
- Continue to act honestly, transparently, and always in the client’s best interests.
Most importantly, obtain the client’s free and informed written consent before providing any additional / optional non-immigration service.
A word of caution
Please note that this article reflects my professional and personal interpretation of the CICC’s Code of Professional Conduct and should not be taken as an official interpretation or position of CICC.
If you intend to provide sophisticated, regulated, or higher-risk ancillary services—or if you simply want complete certainty that your business model complies with the Code—I strongly recommend seeking written guidance from CICC before proceeding.
You may contact the College at:
Explain your proposed business model, the additional services you intend to provide, and the safeguards you have in place to manage potential conflicts of interest. Seeking written guidance from the regulator is always a prudent approach where the Code does not specifically address a particular scenario.
As RCICs, our responsibility is not only to comply with the letter of the Code but also to uphold its underlying principles of independence, transparency, professionalism, and acting at all times in the client’s best interests. Wishing you all the best with your business.
