The New CPA Compliance Map

The CPA profession is in the middle of a major shift in how candidates get licensed and how licensed CPAs can practice across state lines. Over the past couple years, a wave of state legislation has sought to address a shrinking pipeline of new accountants by creating alternative educational pathways into the profession and pairing those changes with updated mobility rules so that CPAs can more freely serve clients across jurisdictions.

The result, however, is not a tidy uniform system. It is a fast-moving, state-by-state patchwork where the details vary enormously and where the status of a given state can change from “legislation introduced” to “in effect” within a single legislative session.

Not Every State Has Changed

The most important thing to understand is that reform is not universal. A number of states are still sitting out entirely or are in the early stages of the process.

Florida introduced legislation in 2026, but it died in committee. This is significant given Florida’s size and the number of CPA firms and candidates operating there.

Other states such as Wyoming, North Dakota, and Maine did not introduce any pathways or mobility changes in the 2026 state legislative sessions.

On the other end of the spectrum, many states have fully enacted both new pathways and updated mobility rules that are already in effect, including Georgia, Kansas, New Mexico, Oregon, Virginia, Pennsylvania, South Carolina, Tennessee, and Washington, among others.

And then there are states in the middle. Legislation has been introduced but not yet passed in Colorado, the District of Columbia, Louisiana, Massachusetts, Michigan, Missouri, New Hampshire, Rhode Island, Vermont, and Wisconsin. For those states, candidates cannot yet rely on any new rules.

The Pathway Details Are Not Uniform

Even among states that have passed new pathway legislation, the specific educational and experience requirements vary in meaningful ways.

The most common model offers candidates three routes to licensure:

• Post-bachelor’s degree plus accounting concentration plus one year of experience
• Bachelor’s degree plus accounting concentration plus 30 additional credit hours plus one year of experience
• Bachelor’s degree plus accounting concentration plus two years of experience

States that have adopted all three of these paths include Arkansas, Connecticut, Delaware, Georgia, Idaho, Illinois, Indiana, Kansas, Mississippi, Nevada, New Mexico, Oregon, South Dakota, Virginia, Washington, West Virginia, and others.

But several states diverge from this template in notable ways.

California offers two paths: bachelor’s plus accounting concentration plus two years, or 150 hours plus one year. But the 150-hour path sunsets in 2029. After that, only the lower-credit path will remain available.

Minnesota offers bachelor’s plus two years or master’s plus one year, with a middle “bachelor’s plus 30 hours” option that sunsets after June 30, 2030. That transitional provision is meant to give the profession time to adjust.

Mobility Guardrails Are Also Not Uniform

When states pass updated mobility rules alongside pathways legislation, they typically establish guardrails: the minimum qualifications an out-of-state CPA must meet to practice in the state without obtaining a local license. Here too, the details vary considerably.

The most permissive approach is no guardrails except for the CPA exam. A CPA licensed in any other U.S. jurisdiction can practice. States with this approach include Alabama, New Mexico, Virginia, Tennessee, Nevada, and others.

Many other states set their mobility guardrails to match their pathways. That means an out-of-state CPA must meet the same educational and experience requirements that an in-state CPA would need. This is the approach taken by Arkansas, Connecticut, Idaho, Illinois, Indiana, Iowa, Kansas, Mississippi, South Dakota, and others.

But some states set guardrails that are more specific or more narrowly drawn.

California is the most distinctive case. The state’s mobility regime does not set traditional guardrails in the legislation. Instead, the California Board of Accountancy retains the authority to vote to require notification and CBA approval for licensees from any specific state it determines does not have comparable licensure requirements. If triggered, an individual from that state must either meet the bachelor’s plus accounting concentration plus one year experience standard or satisfy the 4-in-10 rule, meaning four years of practice in the last ten years.

Pathways and Mobility Do Not Always Move Together

A critical nuance that gets lost in casual coverage of this topic: new pathways, which change who can become a CPA, and updated mobility, which changes how CPAs can practice across state lines, are legally distinct and do not always move together.

Some states have passed one but not the other.

Maryland is a clear example. Maryland already had automatic individual mobility in effect, but pathways legislation has only been introduced, not yet passed. So out-of-state CPAs can already practice there without a local license, but the new lower-credit educational pathway is not yet available to in-state candidates.

Montana updated its pathways through administrative rulemaking, making three educational paths available, but has not updated its mobility rules through legislation. Instead, Montana relies on a board determination system under existing NASBA frameworks, a different and more uncertain mechanism for out-of-state CPAs.

Safe Harbor Provisions Vary Widely

One of the most practically important and most varied elements of these reforms is the safe harbor: what happens to someone who already holds a valid CPA license issued under the old 150-hour rules and who may not technically meet one of the new pathway definitions for mobility purposes?

Many states include an explicit safe harbor keyed to a specific date, ensuring that existing licensees are grandfathered in. But the dates are not consistent across states:

• December 31, 2024: Arizona, Delaware, Idaho, Louisiana (proposed), Massachusetts (proposed), Michigan (proposed), Missouri (proposed), Rhode Island (proposed), South Dakota, Texas, Vermont (proposed), Colorado (proposed)
• December 31, 2025: Arkansas, Kansas, Mississippi, West Virginia
• June 30, 2025: Kentucky, Pennsylvania
• September 30, 2025: Connecticut
• March 18, 2026: Puerto Rico, keyed to the law’s own passage date
• Prior to bill becoming effective: District of Columbia (proposed), New Hampshire (proposed), Wisconsin (proposed)
• Pre-January 1, 2012: Illinois, a legacy safe harbor exempting older licensees from the 150-hour requirement entirely, distinct from the new reform wave

Some states with active legislation offer no safe harbor at all. Georgia, Montana, Nevada, New Mexico, New York, North Carolina, Ohio, Oregon, Utah, Virginia, Washington, and others have no explicit safe harbor language. In some of these states, the mobility guardrails are broad enough that the issue rarely arises. In others, it may create real uncertainty for CPAs whose credentials do not map cleanly onto the new framework.

One Additional Nuance: How “Bachelor’s” Is Defined

Most states do not define what a bachelor’s degree means for pathway purposes. It is assumed to be a standard four-year degree. But a small number of jurisdictions have explicitly defined “bachelor’s” as 120 credit hours in their legislation: Tennessee, Puerto Rico, New York, and Michigan.

This distinction matters because some degree programs, particularly accelerated or professional formats, may confer a bachelor’s degree with fewer than 120 credits. By defining the floor explicitly, these states are setting a minimum academic threshold that the degree label alone does not guarantee.

What This Means for Your Firm

The CPA licensure reform wave is real, significant, and ongoing, but it is not a single unified change. What has actually been enacted varies enormously by state: in the pathway options available, in the experience requirements attached to each path, in whether mobility has been updated at all, in the guardrails governing out-of-state practice, and in the safe harbor protections afforded to existing licensees.

For firms with multi-state practices, for candidates choosing where to sit and where to build their careers, and for educators advising students on what their degree will and will not qualify them for, this complexity is not academic. The state you are in, and the date your license was issued, can determine which doors are open to you.

Staying current requires tracking not just whether a state has “passed something,” but exactly what it passed, when it takes effect, and how its guardrails and safe harbors interact with where your license was actually issued.