Tennessee CPA Renewal: Two Clocks on One Page, Confirmed by the Board

Tennessee runs two different renewal clocks under one roof — and the Board's own renewal page describes them in a way that makes it easy to think there's only one. We asked the Board directly which clock actually applies to firm permits, and got a clear, on-the-record answer. Here's exactly how individual and firm renewal work in Tennessee, sourced to the Tennessee Code, the Board's own rules, and that direct confirmation.

Two clocks: individual certificates run biennial, firm permits run annual

Individual CPA certificates and PA registrations renew every two years. Tenn. Code Ann. § 62-1-107(b) says those dates "may be set by the board at its discretion," and that the renewal process "may include procedures for odd-numbered certificates and registrations" to renew on odd-numbered years and even-numbered ones on even-numbered years. That language allows such a system without saying the Board adopted one, and neither the Board's rules chapter nor its renewal page says how a given certificate's year is set. So check your own license's expiration date and confirm it with the Board.

Firm permits run on a completely separate clock: every single year, always expiring December 31 — regardless of which year your own individual certificate renews. That's set by Tenn. Comp. R. & Regs. 0020-01-.11(2), and we confirmed it directly with the Board rather than relying on the rule text alone: the Board's own Licensing Coordinator told us plainly, "Firm permits expire annually on December 31. There should be no conflicting guidance on official TN websites."

Confirm your own next Tennessee renewal deadline here — individual and firm renewals are tracked separately, since they run on genuinely different cycles.

Why the Board's own page can read like one shared cycle

If you've read Tennessee's renewal-requirements page and come away thinking firm permits follow the same two-year cycle as individual licenses, you're not misreading it by accident. The page's "[Year] Renewal Requirements" heading states: "Renewal applications for CPA/PA licenses and firm permits with an expiration date of December 31, [year] are available beginning November 2, [year]." Read at a glance, that sentence's modifying clause — "with an expiration date of December 31, [year]" — appears to describe both license types sharing one dated expiration in the same year.

It doesn't — the rule itself is unambiguous even if the page's phrasing isn't. We asked the Board's Licensing Coordinator directly, and got a clear answer: firm permits expire annually on December 31, full stop, and there should be no conflicting guidance anywhere on the Board's official site. They also asked us to point them at anything that reads otherwise so they could get it corrected — so we did, flagging this exact page and sentence. Until any wording change goes up, read the sentence above as covering individual licenses with that expiration date and firm permits, which land on December 31 every year without exception. The two share a date in that year, but they don't run on the same schedule.

One more distinction worth knowing: a license that's 1 day to 6 months past its expiration date is "delinquent" (a $100 late fee applies, per 0020-01-.08(6)) — it isn't dead yet. Only past the 6-month mark does a license become "expired" and require full reinstatement (0020-01-.08(7)), covered below.

CPE: 80 hours every 2 years, with a Tennessee-specific ethics course

Tennessee requires 80 hours of CPE per 2-year period immediately preceding renewal, with a minimum of 20 hours completed each year — so you can't bank all 80 in a single year and coast the next. Of those 80 hours, at least 40 must be in technical subjects, and you need a board-approved 2-hour Tennessee-specific ethics course — not just any generic ethics CPE. All four figures are set directly in Tenn. Comp. R. & Regs. 0020-05-.03(1).

See the full Tennessee CPE breakdown here.

The renewal fee: two different numbers for two different clocks

Individuals pay a flat $110 every two years, set at Tenn. Comp. R. & Regs. 0020-01-.04(1)(c) — described in the rule text itself as "biennially," matching the individual certificate cycle above. Firms pay something else entirely: a flat $50 every single year, set two lines below at 0020-01-.04(1)(e) ("Renewal of firm permit... Fifty dollars ($50.00)"). If you're renewing a firm permit, $110 biennially isn't your number at all — budget $50 annually instead.

Either way, renew between 31 days and 6 months late, and a $100 late fee applies on top of whichever renewal fee is yours (0020-01-.04(1)(f) and .08(6)) — but note that fee only attaches starting at day 31 of delinquency, not from the first day you're late.

If a license fully expires: what reinstatement costs

Cross the 6-month delinquent window and a license is "deemed to have expired," which triggers full reinstatement rather than a simple late renewal. Tennessee sets this at a flat $250 reinstatement application fee, codified at 0020-01-.04(1)(g) — "Fee for application for reinstatement Two hundred and fifty dollars ($250.00)."

The CPE side is steeper than a normal renewal: 80 "penalty hours" in technical fields of study, including 2 ethics hours, and all of it has to be earned in the 6 months immediately preceding the reinstatement application — per 0020-05-.03(6). These hours are explicitly labeled penalty hours and can't be recycled toward your next normal renewal cycle's CPE; it's a dedicated 80-hour catch-up on top of whatever you'll owe going forward.

Walk through the full Tennessee reinstatement math here.

Bottom line: know which clock applies to you. Individual certificates and PA registrations renew every two years, for $110, so check your own license's expiration date; firm permits renew every single year on December 31 for $50, confirmed directly by the Board despite renewal-page wording that can read otherwise. Either way, budget 80 CPE hours per 2-year period (20 minimum each year, 2 of them a Tennessee-specific ethics course), and if a license does lapse past 6 months, plan on $250 plus 80 penalty hours earned in the 6 months before you reapply. Set a reminder for your own Tennessee deadline here so you're never the one re-reading that renewal page trying to figure out which clock you're on.

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