Any CPA who works on an audit under Government Auditing Standards, the Yellow Book issued by the US Government Accountability Office (GAO), has to meet continuing professional education (CPE) requirements that sit on top of the state board's rules. The Yellow Book applies to single audits and many other audits of governments, school districts, nonprofits that receive federal funds and other entities. Firms that do this work need to track the hours per person, and peer reviewers look at the records.
This guide reflects the 2024 revision of the Yellow Book (GAO-24-106786), chapter 4, which sets the rules in paragraphs 4.16 to 4.51. See Yellow Book (GAGAS) explained for the wider standard and GAGAS for the definition.
Which Yellow Book applies?
The 2024 revision applies to financial audits, attestation engagements and reviews of financial statements for periods beginning on or after December 15, 2025, and to performance audits beginning on or after that date. Early implementation is permitted. Audit organizations must design and implement a system of quality management by December 15, 2025 and complete an evaluation of it by December 15, 2026. For engagements under the earlier revision, the same 80-hour and 24-hour structure applies, with the 2018 requirements kept in force until the 2024 effective date. See also SQMS 1.
The core requirement
Auditors who plan, direct, perform engagement procedures for, or report on an engagement conducted under GAGAS must complete at least 80 hours of CPE in every 2-year period (paragraph 4.16), made up of:
| CPE hours | Subject matter |
|---|---|
| 24 hours | Subject matter directly related to the government environment, government auditing, or the specific or unique environment in which the audited entity operates |
| 56 hours | Subject matter that directly enhances auditors' professional expertise to conduct engagements |
The 24 hours are part of the 80, not in addition. Auditors must also complete at least 20 hours in each year of the 2-year period (paragraph 4.17), and the audit organization maintains documentation of each auditor's CPE (paragraph 4.18). The 24 hours may be taken at any time in the 2-year period (paragraph 4.20). The 24-hour subjects can count toward the 56 hours, and CPE in a 56-hour subject that is tailored to the government environment can count toward the 24 hours (paragraph 4.22).
Excess hours do not carry over from one 2-year period to the next (paragraph 4.45).
What qualifies as government-related CPE?
The 24-hour category covers, among others (paragraph 4.23):
- GAGAS and related topics, including internal control as addressed in GAGAS
- AICPA auditing, attestation and SSARS standards, and other audit standard-setters' standards
- GAAP and the frameworks of FASAB, GASB and FASB
- Standards for Internal Control in the Federal Government and the COSO framework
- requirements for recipients of federal awards, including Single Audits under 2 CFR part 200, subpart F
- federal, state or local program audits
- IT auditing, forensic auditing and fraud topics in a government setting
- the nature of government: structures, financing, operations, appropriations
- compliance with laws and regulations
The 56-hour category covers those topics plus general ethics and independence, accounting, data analysis, communication skills, leadership, software used on engagements, information technology and similar subject matter (paragraph 4.24).
The audit organization decides whether a subject qualifies for its auditors (paragraph 4.21). Hours from a professional certification review course count only for segments that are relevant to the standards or to the engagement work (paragraph 4.47).
What activities count, and how many hours?
- Structured programs with learning objectives: internal training, conferences, webinars, self-study, accredited university courses and similar (paragraphs 4.32 and 4.33).
- A CPE hour is granted for each 50 minutes of participation (paragraph 4.37).
- College credit courses: each semester unit equals 15 CPE hours and each quarter unit 10 (paragraph 4.38).
- Speakers and instructors can receive hours for presentation and preparation time, up to 40 hours in any 2-year period (paragraph 4.40).
- Published writing can earn one hour per hour of writing, up to 20 hours in a 2-year period (paragraph 4.41).
Who is exempt or covered differently?
- Auditors who charge less than 20 percent of their time annually to GAGAS engagements and only perform engagement procedures, without planning, directing or reporting, can be exempted by the audit organization from the 56-hour requirement, but not the 24-hour one (paragraph 4.25).
- Nonsupervisory auditors who charge fewer than 40 hours a year to GAGAS engagements may be exempted from all CPE requirements (paragraph 4.26).
- Temporary students and interns may be exempted (paragraph 4.27).
- Support staff who do not conduct engagement activities are not auditors subject to the requirement (paragraph 4.28).
- External specialists are not subject to the requirement. Internal specialists who are part of the engagement team, including planning, directing, performing procedures or reporting, are auditors and are subject to it, and CPE in their field of specialization counts toward the 24 hours (paragraphs 4.30 and 4.31).
- Extended absences, such as illness, parental leave, sabbaticals, military service and disasters, may justify a partial exemption. Workload, budget or travel constraints do not (paragraph 4.29).
Proration and grace periods
An auditor hired or assigned to a GAGAS engagement after the 2-year period begins may complete a prorated number of hours, based on the number of full 6-month intervals remaining in the period (paragraph 4.42). The 20-hour annual minimum does not apply when prorating (paragraph 4.43).
Worked example. Illustrative dates. The firm's 2-year CPE period runs January 1, 2026 to December 31, 2027, which has four 6-month intervals. A new auditor joins a GAGAS engagement in April 2026. Three full 6-month intervals remain (July to December 2026, January to June 2027, July to December 2027).
- Total requirement: 3/4 x 80 hours = 60 hours.
- Government-related portion: 3/4 x 24 hours = 18 hours.
At its discretion, an audit organization may give auditors up to 2 months after the end of a period to make up a deficiency in the 80 hours, and up to 2 months after a year to make up the 20-hour annual minimum. Hours used to make up a deficiency cannot count toward the next period, and anyone who has not completed the requirement after the grace period may not participate in GAGAS engagements until they have (paragraph 4.44).
Documentation and monitoring
The firm's CPE policies address identifying who is subject to the rules, offering programs, helping auditors decide what qualifies, recording hours and monitoring compliance (paragraph 4.50). Documentation typically records the provider, program title and subject matter, dates, hours and, for the 24-hour requirement, the government-related category (paragraph 4.51). Keep the records long enough to satisfy legal and administrative requirements, including peer review. The CPE tracking log is a starting layout, and peer review readiness covers what reviewers ask for.
State board CPE for the CPA license is a separate requirement. A course can count for both if it meets each set of rules, and the Yellow Book hours are counted by the firm's measurement period, not by the state's reporting cycle.
Common mistakes
- Counting the 24 hours on top of the 80, not within them.
- Missing the 20-hour minimum in one year while meeting the 2-year total.
- Allowing a staff member to charge to a GAGAS audit before the CPE was current.
- Counting generic courses that are not on audit, accounting or government subjects.
- Giving exemptions for workload, which the standard disallows.
- No record of which 24 hours were government-related.
Frequently asked questions
How many CPE hours does the Yellow Book require?
80 hours every 2 years, including at least 24 hours of subjects directly related to the government environment, government auditing or the audited entity's unique environment, and at least 20 hours in each year.
Do the 24 hours count toward the 80?
Yes. The 24 hours are included in the 80.
Does a staff accountant on a single audit need Yellow Book CPE?
If the person plans, directs, performs engagement procedures for, or reports on the GAGAS engagement, the requirement applies, unless the firm applies an exemption such as the one for nonsupervisory auditors who charge fewer than 40 hours a year (paragraph 4.26).
Can CPE hours carry over?
No. Excess hours cannot be carried to the next 2-year period.
Does the 2024 Yellow Book change the CPE hours?
The 2024 revision keeps the 80-hour and 24-hour structure in chapter 4.
Sources
- GAO, Government Auditing Standards: 2024 Revision, GAO-24-106786, chapter 4, gao.gov/yellowbook
- GAO, Yellow Book page on effective dates of the 2024 revision, gao.gov/yellowbook
- 2 CFR part 200, subpart F, ecfr.gov
Part of CORAA University · Government, single audit and nonprofits: related guides, calculators and templates.
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