Of every state pair covered in this series, Virginia-to-D.C. is the one where the rule is most actively in motion — D.C. rewrote its practice-privilege test by emergency legislation that took effect August 10, 2026 and, by its own terms, expires November 8, 2026. Here's what applies right now, what's grandfathered, and exactly where the ground could shift.
D.C. Act 26-399 (the Business Licensing Reform and Accountancy Practice Emergency Amendment Act of 2026) rewrote D.C. Official Code § 47-2853.49. Under the amended section, an out-of-state CPA whose principal place of business is not in the District has all the privileges of a D.C. licensee with no D.C. license required, provided the individual holds a valid, unrestricted CPA license in good standing from any state, and at the time of initial licensure was required to show evidence of having passed the Uniform CPA Exam (or a Board-approved equivalent) and met education and experience requirements equivalent to D.C.'s own. This replaces the old NASBA/NQAS substantial-equivalency framework with an individual-criteria test — the same direction New Jersey, Connecticut, Texas, and Pennsylvania have all moved in over the past year. An actively-licensed Virginia CPA clears these criteria without difficulty.
There's no notice filing and no fee: the amended section expressly says a privilege holder "need not provide notice or other submission to any individual." Standard conditions attach automatically — consent to the D.C. Board's jurisdiction, compliance with D.C. law, cessation if your Virginia license lapses, and Virginia's board as your agent for service of process.
The amended section carries an explicit grandfather clause: an out-of-state CPA who had D.C. practice privileges under the old rule immediately before August 10, 2026 keeps them, regardless of whether they meet the new criteria.
Here's what most summaries will miss: this is emergency legislation, and D.C.'s own code compilation carries a note that the amendments expire November 8, 2026. A permanent version (Bill 26-494) passed the D.C. Council unanimously in July 2026, but D.C. permanent acts must complete congressional review before taking effect — a process with no fixed end date. If the permanent act (or a bridging temporary act) isn't in force when the emergency act lapses, the section reverts to its prior NASBA-based text until it is. If you're structuring anything that depends on this privilege past early November 2026, re-confirm the rule's status at that time rather than assuming this page's snapshot still holds.
The firm-side rules were not rewritten by the emergency act. A firm with no D.C. office performing attest services (audits, SSARS reviews, SSAE examinations, PCAOB engagements) for a client with its home office in the District must register with the D.C. Board (§ 47-2853.44), and a privilege-holding individual may only perform that work through a registered firm. For non-attest work (tax, consulting), the statute exempts qualifying no-office firms from registration — but D.C.'s older compiled regulations, which predate the mobility era and were never conformed, still read as requiring a permit of every nonresident firm. That statute-vs-regulation conflict is genuinely unresolved; the cautious course for a firm doing ongoing non-attest work for D.C. clients is to confirm directly with the D.C. Board rather than relying on either reading.
The honest caveat: this page is sourced to the amended text of D.C. Official Code § 47-2853.49 as published in the D.C. Law Library following D.C. Act 26-399, and to § 47-2853.44 for the firm rules — not to the D.C. Board's own web pages, which are thin on mobility guidance. The emergency-expiry date above comes from the code compilation's own notice. This is general orientation, not a determination for your specific engagement type — and for this particular pair, anything past early November 2026 deserves a fresh check. Run your own situation through our Practice Privilege Check tool, or confirm with the D.C. Board of Accountancy directly. And keep your own Virginia renewal on track — it's due every June 30. Check your Virginia renewal date here.
General orientation, not a citation. This guide draws on board rules and, where available, this site's own verified dataset — it isn't a primary source in itself. Last checked against those sources: August 13, 2026.
For the current renewal date or CPE figures your state actually enforces, use the state page linked above — it carries a direct link to the board page and codified rule, per our verification standard.