A CPA licensed in one state serves a client in another. Whether that is allowed without a second license is a mobility question, and the answer changed in 2025. The model law moved from asking where a CPA is licensed to asking how a CPA was licensed. This article explains both models, what the transition protects, and the checks a firm makes before it staffs an engagement across a state line.
The old model: substantial equivalency
For years, mobility rested on substantial equivalency. A state treated another state's CPAs as qualified to practice across the line when that state's licensure requirements matched the Uniform Accountancy Act (UAA). The 150-hour education requirement was the centerpiece of that standard. In February 2023, NASBA's board reaffirmed the 150-hour standard, and its leadership warned that a state lowering licensure to 120 hours would lose automatic substantial equivalency, so that its CPAs would no longer be automatically substantially equivalent.
That linkage is why the licensure pathway debate and the mobility debate were one debate. A state that changed its education rule put its CPAs' practice rights in other states in question. Read the companion article on 150-hour rule changes by state for the licensure side.
The new model: individual-based practice privilege
The AICPA and NASBA updated the UAA in July 2025. The ninth edition moves mobility to an individual-based model. The structure is: a CPA holds one home-state license and holds practice privileges in other jurisdictions, and where the privilege applies, no additional application or fees are required.
NASBA's September 2025 mobility update framed the shift this way: mobility is moving from where a CPA is licensed to how a CPA was licensed. A CPA's privilege now depends on that CPA's own education, exam, and experience, not on whether the home state's statute matches the target state's.
The AICPA reported that 25 states had adopted an individual-based model and that at least 10 more planned to introduce legislation in 2026. The AICPA states the broader rule: each jurisdiction decides whether and how to adopt the UAA. A state that has not enacted the ninth edition's mobility provisions applies its existing law.
The safe harbor
The ninth edition includes safe-harbor language. NASBA describes it this way: CPAs licensed under differing education, experience, and exam requirements as of December 31, 2024, keep their practice privileges under mobility. The purpose is to protect licensees already practicing across state lines, including those licensed under older or different requirements, from losing privileges when the model changes.
For a firm this means two populations on the same team: CPAs whose privileges rest on the safe harbor, and later licensees whose privileges rest on their individual qualifications, including the third pathway. See the bachelor's plus two years pathway.
What a practice privilege does not do
- It does not change who regulates the CPA. Oversight and disciplinary authority over licensees stays with the State Board of Accountancy.
- It does not remove the state's rules for the work. Attest services remain restricted to licensed CPAs.
- It does not cover the firm automatically. Firm mobility is treated separately, and adoption varies by state. Check the target state's firm rules.
Before staffing an out-of-state engagement
Run the same short check each time.
- Identify the target jurisdiction and the CPA's home license. Record both on the engagement acceptance form.
- Look up the jurisdiction on CPAMobility.org. NASBA redesigned the site in September 2025 as a continuously updated database of practice privilege rules by jurisdiction. NASBA's Legal and Accountancy Licensing Library researched the summaries, and the state boards verified and approved them.
- Match the privilege to the work. An audit or review is attest work. Record that the privilege covers the services and the report the CPA will sign.
- Assess the firm's own status. If the firm issues the report, apply the target state's firm requirements separately from the individual CPA's privilege.
- Document the answer in the file. Put the lookup, the date, and the conclusion in the planning documentation next to the engagement letter. See audit engagement letter and audit planning memo.
- Re-check at continuance. State laws changed through 2026 sessions. A conclusion from last year's file is stale.
Why it matters for small firms
Mobility is a capacity lever. A firm with a licensed CPA in one state and a client base in two or three can serve those clients without a second license for each reviewer, where the target state has adopted the model. Combined with supervised preparation support, it widens the set of engagements a small firm accepts; see CPA talent shortage and capacity strategies. The firm owns the compliance check, and the file shows it was done.
Mobility rules keep moving as states act, so the lookup belongs in the continuance checklist, not in a one-time memo.
Sources
- AICPA, Uniform Accountancy Act landing page
- AICPA, State policy trends shaping accounting in 2026
- NASBA, AICPA and NASBA Publish Ninth Edition of the UAA
- NASBA, New CPA Licensure Pathways and CPA Mobility
- Journal of Accountancy, Practice mobility update: new NASBA tool tracks changes for CPAs
- Journal of Accountancy, NASBA upholds 150-hour education requirement for CPA licensure
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