Tennessee Firm Mobility
- Based on State Board communications, firms without a physical presence in Tennessee do not need to register to perform attest services.
- Firms still need to be licensed in their home state and enrolled in peer review.
What the statute says
Tennessee’s accountancy act explicitly references firm permits for attest services twice.
T.C.A. § 62-1-108(a) states:
“A firm must hold a permit issued under this section in order to provide attest services or to use the title ‘CPAs,’ ‘CPA firm,’ ‘PAs’ or ‘PA firm.’”
That requirement is reinforced by T.C.A. § 62-1-113(d),(f), which bars any firm without a valid § 62-1-108 permit from providing attest services or using a protected title. Neither provision mentions a physical office location requirement.
T.C.A. § 62-1-117 grants practice privileges to out-of-state CPAs, letting them serve Tennessee clients without obtaining a Tennessee certificate or permit. But § 62-1-117 speaks to individual licensees, not firms.
Every state requires that attest services are performed through a licensed CPA firm. While some states allow out-of-state firms to do this through their home state license, nothing in the Tennessee statute seems to indicate a firm mobility privilege for out-of-state firms.
What Board staff told us
Some firms have received guidance from the Tennessee Board of Accountancy that out-of-state firms do not need a reciprocal firm license to perform attest services, despite what the statute says. CPA QualityPro submitted the question through TDCI’s “Ask TDCI” channel, laying out both statutes and asking whether out-of-state CPA firms need a permit to provide attest services or use the CPA firm title. Department staff responded:
“A Tennessee firm permit is required if a firm has a physical location in our state and a firm licensed in another state may serve a Tennessee client through mobility. If an out of state firm is performing attest services for a Tennessee client, the firm must be authorized to perform attest functions in their home state and enrolled in peer review. A Tennessee firm permit is required if the firm establishes a physical location [in] Tennessee.”
In other words: according to Board staff, an out-of-state firm doing attest work for a Tennessee client only needs a Tennessee firm permit if it opens a physical location in the state. Short of that, home-state authorization and peer-review enrollment are enough.
Why this gap matters
§§ 62-1-108(a) and 62-1-113(d), (f) are still state law. The statute, read on its face, requires a Tennessee firm permit for attest work regardless of where the firm is physically located. Board staff say otherwise, but caveat that their answer isn’t legal interpretation. Neither the Board’s website, rules, nor the statute itself carve out the physical-location exception described, and no additional citation was offered.
Given that board staff have responded to the inquiry in writing, firms can choose to rely on the board’s interpretation. However, future board staff and members could interpret the statute differently and change how they interact with out-of-state firms. Firms should remain aware that Tennessee firm mobility is not explicit in statute or board rule and stay up to date on board communications and rule changes.
We’ll update this post if TDCI or the Tennessee State Board of Accountancy issues formal guidance.
