Questions Every CPA Firm Should Be Asking Its Staff Right Now

The wave of state legislation reshaping CPA licensure and mobility is creating real compliance risk for firms because most staff do not know the right questions to ask. Whether someone is a candidate working toward their first license or a seasoned CPA who has been practicing across state lines for years, the changing landscape affects them.

Here are the questions your firm should be asking both groups right now.

For New CPA Candidates

1. What licensure path are you planning to use, and have you confirmed it is available in your state?

Many states have introduced new alternative pathways to licensure, but they are not available everywhere. Florida’s reform legislation died in committee in 2026. Wyoming, Maine, North Dakota, and others have not enacted changes at all.

Even in states that have passed legislation, the new paths may not yet be in effect if the board still needs to complete a rulemaking process. Do not assume that because a state passed something, a candidate can use it today. Candidates should confirm the paths available with the state board of accountancy where they intend to reside or have their principal place of business.

2. What is your timeline for getting licensed, and will your chosen path still be available when you are ready?

Some of the new alternative pathways have built-in expiration dates. California’s 150-hour path sunsets in 2029. Minnesota’s middle “bachelor’s plus 30 hours” option sunsets after June 30, 2030.

A candidate who works for several years before applying due to life circumstances may find the path they intended to use is no longer on the table. Make sure candidates understand not just what options exist today, but which ones will still exist when they are ready to sit for the exam.

3. Will your licensure path be recognized in the states where you will actually serve clients?

This is where the real complexity lives. Some states have set mobility guardrails that specify which educational and experience backgrounds they will accept from out-of-state CPAs, and those guardrails do not always align with what other states allow for in-state licensure.

A candidate who gets licensed in one state under a particular path needs to understand whether that path will be recognized in every state where they will be serving clients.

4. How many credit hours did your bachelor’s degree actually include, and does your state have a minimum?

Most states assume a bachelor’s degree equals approximately 120 credit hours, but a small number, including Tennessee, New York, Puerto Rico, and Michigan, have explicitly defined a bachelor’s degree as requiring 120 credit hours for licensure purposes.

Candidates who completed accelerated programs, online-only programs, or newer degree formats may have earned a credential that carries the title of “bachelor’s degree” but falls below that threshold. If your state has codified the 120-hour minimum, those candidates will need additional credits before they can qualify, and they may not realize it.

5. Do you meet the updated accounting concentration requirements for your state?

Alongside the headline changes to credit hour requirements, many states have quietly updated what they require within the accounting concentration itself, including the specific subject matter that coursework must cover.

These updates are less visible than the overall credit hour debates, but they matter just as much. A candidate who graduated several years ago, or who took a non-traditional academic path, may find that their coursework satisfies the old concentration standard but falls short of the new one. It is worth confirming that coursework maps to current requirements, not the rules that were in place when the candidate started their program.

For Existing CPAs

6. Do you know exactly how you met your licensure requirements?

This used to be a question with an obvious answer: you completed 150 credit hours, passed the exam, and got your license.

But as more states shift toward mobility frameworks that are based on individual qualifications rather than simply recognizing any valid out-of-state license, the specifics of how someone got licensed are starting to matter again. A CPA who got licensed years ago under a now unavailable path, or whose educational background does not clearly map to one of the new pathway categories, may find themselves in a gray area when practicing in states with stricter mobility guardrails.

Staff should know how they qualified, not just that they did.

7. Do you have a current list of every state where you practice but do not hold a local license?

Mobility rules are changing faster right now than at any point in recent memory, and the compliance picture is shifting beneath firms’ feet. A state that was fully open to out-of-state practice last year may have new guardrails or notification requirements today. A state where your staff regularly serves clients under mobility may be one of the states where legislation is still pending, meaning the rules could change mid-engagement.

Firms should maintain an active, up-to-date accounting of where each CPA on staff is practicing under mobility rather than under a local license, which services that CPA is providing, and whether those activities still fit the applicable state rules. That list should be reviewed regularly, not just at license renewal time.

The Through-Line

The through-line across all of these questions is the same: the changes happening right now are not self-executing. They require firms to actively understand their staff’s individual situations, including education, timelines, and client footprints, and to stay current as the legislative landscape continues to evolve state by state.