CPA Mobility & Practice-Privilege Rule Changes

A running feed of confirmed and pending changes to interstate CPA mobility rules — practice privileges, notice/fee requirements, and firm registration — sourced the same way as every other date on this site: a citation to the primary statute or rule, never a guess. Our automated day-to-day monitoring hasn't flagged and promoted a confirmed change yet — that's expected in the early days of a new monitor watching mostly-static legal text, not a sign the feed is broken. Every item below instead comes from our batch legal research.

Upcoming changes (9)

A dated, signed change that hasn't taken effect yet.

Colorado Enacted

Effective August 12, 2026 — not yet in force.

Colorado's CPA mobility rule is changing to state-level substantial-equivalence mobility (based on the practitioner's home state's overall status). See the citation below for the exact requirements.

Colo. Rev. Stat. §§ 12-100-114(1),(7), 12-100-116(1), 12-100-117(2); 3 CCR 705-1, Rules 1.11, 1.14, 1.15; as amended by SB 26-076 (Ch. 81, Sess. Laws 2026), § 12-100-117(2)(a)(I), eff. 2026-08-12 · dual-source legal research, confidence: dual_source

Missouri Enacted

Effective August 28, 2026 — not yet in force.

Missouri's CPA mobility rule is changing to state-level substantial-equivalence mobility (based on the practitioner's home state's overall status). See the citation below for the exact requirements.

RSMo § 326.283 (individual practice privilege); RSMo § 326.289 (firm permits); 20 CSR 2010-2.022 (Privilege to Practice) · dual-source legal research, confidence: dual_source

Alabama Enacted

Effective October 1, 2026 — not yet in force.

Alabama's CPA mobility rule is changing. See the citation below for the exact requirements.

Ala. Code § 34-1-7 (practice privilege; Act 2009-620 scheme); Ala. Code §§ 34-1-6, 34-1-10, 34-1-11, 34-1-16(12) (firm registration/permits, attest exception); Ala. Admin. Code r. 30-X-3-.04 (Mobility); all as amended by HB59, 2026 Reg. Sess. (Pathways to CPA Act), eff. 2026-10-01 · dual-source legal research, confidence: dual_source

Oklahoma Enacted

Effective November 1, 2026 — not yet in force.

Oklahoma's CPA mobility rule is changing. See the citation below for the exact requirements.

59 O.S. § 15.12A (individual practice privilege; firm non-attest privilege at (A)(4)); 59 O.S. § 15.15(A)(3) and § 15.15C (out-of-state firm attest exemption); 59 O.S. § 15.30 (quality/peer review); as amended by Laws 2023, SB 172, c. 26 (eff. 2023-11-01) and Laws 2026, HB 4317, c. 186 (eff. 2026-11-01) · dual-source legal research, confidence: dual_source

New York Enacted

Effective November 21, 2026 — not yet in force.

New York's CPA mobility rule is changing. See the citation below for the exact requirements.

N.Y. Educ. Law § 7406(2) (practice privilege); §§ 7408, 7410 (firm registration and peer review); 8 NYCRR 70.7 · dual-source legal research, confidence: dual_source

Arizona Enacted

Effective January 1, 2027 — not yet in force.

Arizona's CPA mobility rule is changing. See the citation below for the exact requirements.

A.R.S. § 32-725 (limited reciprocity privilege; individuals and out-of-state firms); A.R.S. § 32-731 (CPA firm registration); as amended by Laws 2026, Ch. 17 (SB 1181, Certified Public Accounting Act of 2026) eff. 2027-01-01 · dual-source legal research, confidence: dual_source

Illinois Enacted

Effective January 1, 2027 — not yet in force.

Illinois's CPA mobility rule is changing. See the citation below for the exact requirements.

225 ILCS 450/5.2 (with 225 ILCS 450/13, 14, 14.4, 16); 68 Ill. Adm. Code 1420.75 · dual-source legal research, confidence: single_source

Indiana Enacted

Effective January 1, 2027 — not yet in force.

Indiana's CPA mobility rule is changing to state-level substantial-equivalence mobility (based on the practitioner's home state's overall status). See the citation below for the exact requirements.

Ind. Code § 25-2.1-4-10 (individual practice privilege, no notice); Ind. Code §§ 25-2.1-12-5 and 25-2.1-12-2 (firm permit required for attest services/CPA title use); Ind. Code § 25-2.1-5-8 and 872 IAC 1-6-9 (peer review as condition of firm permit renewal) · dual-source legal research, confidence: dual_source

Massachusetts Enacted

Effective January 1, 2027 — not yet in force.

Massachusetts's CPA mobility rule is changing to state-level substantial-equivalence mobility (based on the practitioner's home state's overall status). See the citation below for the exact requirements.

M.G.L. c. 112, § 87B(h)(2)-(3); § 87D(a), (m); § 87B1/2(k); St. 2020, c. 319 (Act Modernizing Public Accountancy, approved 2021-01-11) · dual-source legal research, confidence: dual_source

Recently changed, pending re-verification (1)

The effective date has passed. We re-verify against the primary source before treating a post-change rule as settled — we do not assume a law took effect just because its start date arrived.

Louisiana Enacted

Effective August 1, 2026 — passed; we re-verify on or after that date before treating it as settled, not asserting it took effect from this record alone.

Louisiana's CPA mobility rule is changing to individual-criteria mobility (based on the practitioner's own license and experience, not their home state's status). See the citation below for the exact requirements.

La. R.S. 37:94 (individual practice privileges); La. R.S. 37:77 (firm permits/exceptions); LAC 46:XIX.1105(E) (no-notice/no-fee rule); LAC 46:XIX.1501(B) (firm no-permit conditions) · dual-source legal research, confidence: dual_source

Sources under active disagreement (7)

For these jurisdictions, our two primary sources currently state different rules for the same question. We withhold a determination rather than pick a side until the conflict resolves — these are not confirmed rule changes.

District of Columbia Sources disagree

Our two primary sources for District of Columbia currently disagree about its mobility rule. We withhold a determination rather than pick a side until this resolves.

D.C. Official Code § 47-2853.49 (substantial equivalency; practice privilege); § 47-2853.44 (registration of firms of certified public accountants); 17 DCMR §§ 2541, 2542, 2546, 2548, 2550

Guam Sources disagree

Our two primary sources for Guam currently disagree about its mobility rule. We withhold a determination rather than pick a side until this resolves.

22 GCA § 35122 (Substantial Equivalency), Guam Accountancy Act of 2003; firm permits at 22 GCA § 35107; implementing rules at 25 GAR §§ 2103(d), 2106, 2112

Michigan Sources disagree

Our two primary sources for Michigan currently disagree about its mobility rule. We withhold a determination rather than pick a side until this resolves.

MCL 339.727a (individual practice privilege, no notice/fee); MCL 339.728(1), (4), (5) (firm licensure trigger = in-state office; no-license out-of-state firm practice incl. attest); MCL 339.729(2) (peer review condition); MCL 339.734a (conditions of privilege). Occupational Code, 1980 PA 299, Art. 7.

Northern Mariana Islands Sources disagree

Our two primary sources for Northern Mariana Islands currently disagree about its mobility rule. We withhold a determination rather than pick a side until this resolves.

4 CMC §§ 3401-3440 (Accountancy Act of 2002, PL 13-52), esp. 4 CMC § 3401 (definitions), § 3422 (issuance/renewal of certificates), § 3423 (firm permits to practice); NMIAC §§ 1-10-801 (interstate practice), 1-10-2301 to 1-10-2310 (substantial equivalency/notification), 1-10-1605 (fees)

Oregon Sources disagree

Our two primary sources for Oregon currently disagree about its mobility rule. We withhold a determination rather than pick a side until this resolves.

ORS 673.153 (holders of licenses issued by other states); ORS 673.160 (registration of business organizations); ORS 673.455 (peer review); ORS 673.010(20) ("Substantially equivalent") -- all as amended by Or. Laws 2025 ch. 132 (SB 797), effective 2026-01-01; implementing rules OAR 801-005-0010, 801-010-0080, 801-010-0345, 801-050-0020 (BOA 1-2026, filed 01/29/2026, eff. 02/01/2026)

Puerto Rico Sources disagree

Our two primary sources for Puerto Rico currently disagree about its mobility rule. We withhold a determination rather than pick a side until this resolves.

Ley Núm. 293 de 15 de mayo de 1945, según enmendada ("Ley de Contabilidad Pública de 1945"), Sec. 4 (20 L.P.R.A. § 775) [privilegio de ejercer / equivalencia sustancial]; Sec. 5 (20 L.P.R.A. § 778) [registro de firmas]; Sec. 6 (20 L.P.R.A. § 779) [licencias]; Sec. 18(12) (20 L.P.R.A. § 772) [definición de "Práctica de la Contabilidad Pública"]; as last amended by Ley Núm. 174-2025 (P. del S. 642, approved 19 Dec 2025)

US Virgin Islands Sources disagree

Our two primary sources for US Virgin Islands currently disagree about its mobility rule. We withhold a determination rather than pick a side until this resolves.

27 V.I.C. ch. 5A sec. 250q (Substantial Equivalency); firm permits at 27 V.I.C. ch. 5A sec. 250d, enacted by the Public Accountancy Act of 2014, Act No. 7596 (Bill No. 30-0279, 30th Legislature)