Continuing professional education looks simple until a firm has staff licensed in several states, a mix of audit and tax work and a reporting period that does not match the calendar year. The rules that matter come from the licensing board, not from the course provider, and a firm that plans from the board's rule avoids the unpleasant discovery that hours do not count. This article explains who sets what, shows how a state's rule is structured using Arizona as a worked example and describes a tracking system.
Who sets the rules
The AICPA states that CPE standards for CPAs are established jointly by the AICPA and NASBA. It also states that state boards of accountancy have the final authority on the acceptance of individual courses for CPE credit, and advises CPAs to contact their state boards to confirm their specific requirements. The practical rule for a firm is that the board of the state that issued the license decides whether a course counts. A course listed by a national sponsor can still be rejected, and a board rule can be stricter than the sponsor's description.
NASBA also operates a CPE Audit Service that helps boards audit compliance and lets CPAs report CPE hours and documentation electronically, as a benefit for participating boards. The NASBA page notes that 16 boards use it. Whether a firm's states use it affects how records are requested.
A NASBA post dated May 20, 2026 announces that NASBA and the AICPA approved revisions to the Statement on Standards for Continuing Professional Education Programs. The standards govern sponsors and programs, and the state board rule still decides what counts for each license, so track the board's own publication of any change.
How credit is measured
Credit is based on a 50-minute hour. The AICPA says credit is recommended based on the NASBA word-count formula or pilot testing, with the runtime or the average pilot-tester time divided by 50 to get the credit amount. State rules add their own measurement terms. In Arizona's rule, a class hour is a minimum of 50 continuous minutes of instruction, a half-class hour requires at least 25 continuous minutes and a one-fifth class hour requires at least 10. Other boards set different rules for fractional credit, so use the board's text when a course is shorter than an hour.
A worked example of structure: Arizona
Arizona's rule, Ariz. Admin. Code section R4-1-453, illustrates the layers a state rule can contain:
- Total hours. Registrants whose last registration period was two years must complete 80 hours, and shorter periods can be prorated by quarter, except for ethics.
- Subject minimums. At least 40 hours in accounting, auditing, taxation, business law or consulting services, including at least 16 hours in accounting, auditing or taxation.
- Delivery method. At least 16 hours in classroom, interactive live webinar or lecturing.
- Ethics. Four hours, including at least one hour on the AICPA Code of Professional Conduct and one hour on the Board's statutes and administrative rules. Ethics taught or developed by an employer or co-worker does not qualify.
- No annual minimum. The rule applies its requirements to the two-year period.
- Records. Retain CPE records for three years from the date the registration was dated as received by the Board, including transcripts, course outlines and certificates of completion.
The lesson is the pattern: total hours, subject mix, delivery method, ethics content, proration and records. Every state has its own version of each layer. Read the board's current rule for each license the firm's staff hold, and record the specifics in the firm's CPE policy.
Government auditing and other credentials
Some engagements carry separate CPE requirements. Yellow Book engagements, for example, require specific CPE for auditors who work on them. See Yellow Book CPE: 80-hour and 24-hour requirement. Other credentials, such as the CIA, CISA and CFE, have their own programs. See CPA vs CIA vs CISA vs CFE. Map each person's requirements by credential and by jurisdiction.
Building the firm's CPE system
- Inventory licenses. For each professional: state or states, license type, reporting period end date and any special requirements.
- Record the rule. For each state, a one-page summary with the board's text cited: total hours, subject mix, ethics, delivery method, fractional credit rules, carryover and retention.
- Plan against the firm's work. Compare staff roles to technical needs: new standards, clients' industries, tax law changes, ethics and independence. See staff training plans.
- Budget time and money. Put CPE time on the capacity plan so it is not squeezed out in busy season. See audit busy-season capacity planning.
- Choose providers. Confirm the provider's sponsor status and that the course format and subject area meet the board's rule. See free CPE for CPAs and what counts.
- Track completion. A central log with course, date, hours, field of study, provider, format and certificate location.
- Review before deadlines. A quarterly review of each person's position against the board's requirement, with a reminder well ahead of the period end.
- Retain evidence. Store certificates and outlines for the period the board requires, and longer if the firm's policy says so.
Internal training that can count
A firm's own training may qualify if it meets the board's program requirements, such as preparation, instruction, attendance records and measurement. The Arizona example shows the limit: ethics taught or developed by an employer or co-worker does not qualify there. Confirm the board's rule before counting in-house sessions, and keep the session records.
Mobility and multi-state staff
Staff working under practice privileges or with licenses in several states may face more than one set of rules. See CPA mobility and practice privileges across state lines. Track the home state license as the main requirement and check each other state separately.
FAQ
Does a NASBA-registered course always count?
Not necessarily. State boards have the final authority on acceptance of individual courses.
Is credit measured in hours or minutes?
Credit is based on a 50-minute hour, with fractional credit rules set by the board.
How long should CPE records be kept?
Keep them for the period the board requires. Arizona's rule is three years from the date the registration was dated as received by the Board.
CORAA prepares ready-to-review audit files for US CPA firms; see /us.
Sources
- AICPA and CIMA, CPE requirements and credits: https://aicpa-cima.com/help/cpe-requirements-and-credits
- Ariz. Admin. Code section R4-1-453, Continuing Professional Education: https://www.law.cornell.edu/regulations/arizona/Ariz-Admin-Code-SS-R4-1-453
- NASBA, CPE Audit Service: https://www.nasba.org/products/cpe/
- NASBA, NASBA/AICPA Approve Revisions to the Statement on Standards for CPE (May 2026): https://nasba.org/blog/2026/05/19/approved-revisions-to-standards-2026/
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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