Mobility Compliance Gaps: What Happens When There’s No Safe Harbor?

When firms ask us about CPA mobility, the questions are rarely simple. A recent client inquiry highlighted a compliance scenario that isn’t obvious on the face of any state statute — and one that warranted going directly to the source.

The Question Firms are Asking

Last year, Oregon, along with most of the rest of the states, updated its licensure pathways and substantial equivalency rules to recognize three licensure pathways for out-of-state CPAs practicing under mobility:

This allows for a tremendous amount of flexibility for newly licensed CPAs coming into the profession. The Oregon Board of Accountancy is committed to maintaining a strong mobility system and supporting growth in the CPA pipeline. 

But a client came to us with a practical problem: what about CPAs who were initially licensed in the 1990s, when some states allowed a bachelor’s degree plus only one year of experience? That older pathway doesn’t map neatly to any of the three options above. And unlike many states that have added “safe harbor” language explicitly grandfathering in older licensure paths, Oregon’s statutes don’t include that kind of provision.

So we did what any compliance platform should do: we asked.

Thanks to the responsiveness of the Oregon Board, we were able to confirm that the Board intends to continue to interpret the statute to allow CPAs licensed under historical paths to practice under mobility. 

Why this matters for firms — and why we exist

The answer above is well-reasoned and comes directly from the relevant regulatory authority. It’s also not written anywhere a firm would easily find it.

Oregon’s statutes don’t include the explicit safe harbor language that signals a clean “yes” to firms reviewing their mobility obligations. A compliance officer relying solely on the text of ORS 673.010 could reasonably flag CPAs with 1990s-era licensure as a potential mobility issue in Oregon. 

This is exactly the kind of gap that CPA QualityPro is built to close. Our platform doesn’t just surface state statutes — it incorporates board guidance, regulatory clarifications, and context like this to give firms an accurate picture of where their staff can practice and under what conditions. When a question like this comes in, our job is to get the right answer and make sure it’s accessible the next time a firm needs it.

We’re grateful to the Oregon Board for their transparency and responsiveness. Boards like Oregon’s — that prioritize clarity and accessibility for the profession — make the compliance landscape better for everyone. Our role is to make sure that clarity reaches the firms that need it.