CPA Experience Verification: What the Supervising CPA Attests To

Every CPA license rests on three things: education, the exam, and experience. The first two are verified by a university and by NASBA. The third is verified by you, a licensed CPA who supervised the candidate. Your signature on the experience form is a statement to a state board. This article covers what that statement contains, using a published board form as the worked example, and the records a firm keeps so the statement is supportable.

Experience is defined by the board, not by the model law

The Uniform Accountancy Act gives the length of experience, one year on the graduate and 150-hour pathways and two years on the new bachelor's pathway. The AICPA and NASBA left the content to the states: the new pathway gives jurisdictions a broader role in defining experience, and an earlier competency-based experience framework was tabled after feedback. See the bachelor's plus two years pathway.

So there is no single national experience form. The board that issues the license sets what counts, who can verify, and how the verification is submitted. Use the issuing board's current form, not the form from the state where the candidate works.

A worked example: California Form 11A-6

The California Board of Accountancy publishes the Certificate of Attest Experience (Private Industry or Government), Form 11A-6. It is one board's form, and it shows the structure of a verification.

Who signs. The supervising individual must hold a current, active, and unrestricted license to practice public accountancy, and must provide additional information about the applicant's experience if the board asks for it.

The experience itself. An applicant who wants authority to sign attest reports needs at least 500 hours of attest experience, satisfactory to the board, in addition to 12 months of general accounting experience. Attest engagements include audits, reviews of financial statements, and examinations of prospective financial information.

What the board can ask for later. Section 69 of the California regulations lets the board require an explanation of any representation on the certificate and inspect the documentation relating to the applicant's fulfillment of the experience requirement.

What the supervising CPA is actually vouching for

Strip out the board-specific language and every verification covers the same four statements:

1. Dates. The candidate worked under you from this date to this date, at this level of hours.
2. Work. The candidate performed the described tasks on real engagements.
3. Supervision. You, or a supervisor you name, reviewed that work as it was performed, and had the authority to correct it.
4. Quality. The work met the standards the board asks about.

The signer can only attest to what the file shows. A signature on a form with no supporting record exposes the signer.

Records that make the signature supportable

Build the record while the candidate works, not at the end.

• Engagement log. For each engagement: name, period, candidate role, procedures performed, hours, reviewer.
• Review evidence. The workpaper sign-offs and review notes in the file already show that review occurred. See audit working papers and how to document audit procedures.
• Supervisor identity. Record who supervised each period, their license number, and the issuing state, so a form can be completed after the supervisor leaves.
• Retention. Keep the log with the personnel file for the length of time the firm keeps licensure records, set by firm policy. For engagement files, see audit record retention.

Common failure points

• Wrong supervisor. The verifier is not a licensed CPA, or the license is not active. The verification does not meet the form's signer requirement.
• Experience outside the definition. The candidate's hours are tax or bookkeeping work when the board requires attest work.
• Missing dates. Part-time hours are not totaled.
• Late request. The candidate leaves, the supervisor leaves, and nobody holds the record.
• Rubber-stamping. The supervisor signs without reviewing. The signature is a certification to the board.

Why this matters more with a two-year pathway

The new pathway doubles the experience period. More candidates spend more time in your firm's files before they sign anything themselves. The same file that supports your audit opinion supports the candidate's license. A firm that prepares and documents work in a standard way produces both. See CPA talent shortage and capacity strategies.

Sources

• California Board of Accountancy, Certificate of Attest Experience (Private Industry or Government), Form 11A-6
• California Board of Accountancy, CPA Licensure Experience Requirements
• NASBA, AICPA and NASBA Advance Public Protection-Focused and Market-Responsive Model Licensure Legislation
• NASBA, New CPA Licensure Pathways and CPA Mobility
• AICPA, Uniform Accountancy Act landing page

CORAA prepares ready-to-review audit files for US CPA firms from client books; you review and sign. See /us.

AU-C references are to AICPA Professional Standards, paraphrased here; read the standard itself before relying on a requirement. This page is guidance, not professional advice. Report an error