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Law firm bookkeeping: trust accounting the LSO way, general books that keep pace
Trust money is not your money, and the Law Society expects your records to prove it every single month. Law firm bookkeeping runs two parallel systems — LSO-compliant trust records reconciled three ways within 25 days of month-end, and general books that handle WIP, disbursements, and HST correctly. We maintain both for Ontario firms and sole practitioners.
By the AnalytIQ Accounting team · Last reviewed: August 12, 2026
Two sets of books, one firm
Every practice that holds client money runs two accounting systems, whether it means to or not. The trust side records funds you hold for others — retainers not yet earned, real estate closing money, settlement proceeds — and it is governed by LSO By-Law 9 down to the specific journals and ledgers you must keep. The general side is a normal business: fees billed, disbursements, payroll, HST, and partner draws or corporate salary.
The cardinal rule is that the two never blur. Money moves from trust to general only when fees are properly billed, and no individual client trust ledger may ever go negative — an overdraft on one client's ledger is a shortage of another client's money even when the bank balance looks healthy. We work in Clio, PCLaw, CosmoLex, or QuickBooks Online paired with Clio; the software matters far less than the discipline behind it.
The monthly trust comparison, done by the 25th
By-Law 9 requires a trust comparison every month, completed within 25 days of month-end — and it is the first document an LSO spot auditor asks to see. It is a three-way match:
- The reconciled trust bank balance — statement balance adjusted for outstanding deposits and cheques.
- The trust journal — every receipt and disbursement, in order, with client and matter identified.
- The client trust listing — each client's ledger balance, totalled to the penny.
All three must agree, and the comparison must be retained. We prepare it on schedule, investigate discrepancies — a stale certified cheque, a deposit posted to the wrong matter — and document the fix rather than plugging the difference. We also confirm the housekeeping around mixed trust accounts, including interest directed to the Law Foundation of Ontario.
Disbursements: recoverable, overhead, and the HST line between them
Not all disbursements are equal, and billing them wrong creates both margin leaks and HST errors. The treatment turns on whether the firm paid as agent for the client or as principal.
| What you paid for | How it was incurred | HST when you bill it |
|---|---|---|
| Court filing and government registry fees | As agent for the client | Passed through with no HST added |
| Experts, process servers, couriers | As principal | Rebilled with HST; the ITC is claimed on the cost |
| Photocopies, postage, routine office charges | Overhead recovered as a charge | HST applies; many firms fold these into fees instead |
| Disbursements unbilled at month-end | Carried on the balance sheet by matter | None until billed — but track them or lose them |
We tag every disbursement to its matter when incurred, so recoverable amounts actually get recovered. Unbilled disbursements sitting on aging files are one of the most common leaks we find when we take over a firm's books.
WIP after the end of billed-basis accounting
Since the 2017 federal budget phased out billed-basis accounting for professionals, law firms must include work in progress in income at the lower of cost and fair market value — you can no longer be taxed only when you bill. That makes WIP a real ledger balance that needs a real month-end process: time captured, cost determined, and the year-end figure supportable.
Contingency files are the exception that matters. Where the arrangement gives you no right to bill anything until the matter resolves, CRA accepts that there is nothing to include until that right arises. The books must keep contingency WIP visibly separate from hourly and block-fee WIP so the two are never mixed at year-end.
The general books: draws, HST, and a close that keeps pace
On the general side we run a standard monthly close: receivables aged and chased, HST reconciled on fees and principal-basis disbursements, payroll for staff, and draws or salary-dividend tracking for the partners or the professional corporation. Fee income, disbursement recoveries, and trust transfers each keep their own lanes so the P&L means something.
Firms with US clients or US-source fees add a layer — withholding forms, treaty positions, and the Reg 105 mirror image — which we cover in our cross-border tax guide for lawyers. For how our monthly close works across every engagement, see our bookkeeping services page.
Source: Law Society of Ontario — By-Law 9.
Common questions.
Can you prepare our monthly LSO trust comparison?
Yes. We prepare the three-way comparison — reconciled trust bank balance, trust journal, and client trust listing — inside the 25-day By-Law 9 window, and we investigate and document discrepancies rather than plugging them.
How should disbursements be treated for HST?
It depends on whether the firm incurred them as agent or as principal. True agent disbursements like government filing fees pass through without HST; principal costs like experts and couriers are rebilled with HST while the firm claims the ITC.
Do we still pay tax on unbilled WIP?
Generally yes — since billed-basis accounting was phased out, WIP is included in income at the lower of cost and fair market value. Contingency files with no right to bill until resolution are the main exception.
Related reading
Trust records that pass the spot audit.
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