Capitol Report | Spring 2022
CPA License Renewal: Looking Back and Ahead
At the close of a challenging CPA license renewal cycle, new developments and ongoing improvement efforts aim to make the 2024 renewal process smoother.
Marty Green, Esq.
ICPAS VP of Government Relations
Now that the 2021 CPA license renewal is behind us, it’s time to address some continuing education changes set to impact your 2024 renewal. Don’t panic: The changes are mostly positive.
As you already know, this past renewal cycle was protracted due to the IT issues with the Illinois Department of Financial and Professional Regulation’s (IDFPR) new online portal. The IDFPR’s director issued the first variance extending CPA license expiration from Sept. 30, 2021, to Dec. 30, 2021, and then again to Jan. 31, 2022, but advised that continuing professional education (CPE) for 2021 renewals would still have to be completed by September 30. Subsequently, the IDFPR pivoted and informed the Illinois CPA Society (ICPAS) that CPE had to be completed by the time of renewal—that is, it could’ve been completed up until January 31. Legally speaking, when you renew your license, you’re attesting that you’ve completed 120 hours of CPE at the time you renew.
For the 2024 license renewal, CPAs will still need to complete 120 hours of CPE within the three-year renewal window. Typically, CPA licenses expire on September 30 of a renewal year and the CPE window resets on that day. But for this next renewal cycle, any CPE hours accrued beyond Sept. 30, 2021, can be used for either the 2021 renewal or the 2024 renewal, but they cannot be used for both. Ensure your CPE records and documentation are in order for your 2021 renewal and keep careful track of new hours earned moving forward for audit purposes.
The second CPE item of interest relates to sexual harassment prevention training. Previously, CPAs had a CPE sexual harassment prevention training requirement and an annual requirement to receive training from your employer in accordance with the Illinois Human Rights Act. In the first instance, Public Act 100-762 required occupational and professional license holders to complete one hour of CPE on sexual harassment prevention training provided by a licensed CPE provider repeated each renewal cycle. In the second, Public Act 101-0221 required employers to provide sexual harassment prevention training annually to employees.
In 2021, the General Assembly passed Public Act 102-308, which expanded approved training options for these CPE requirements to include sexual harassment prevention training developed or offered by the Illinois Department of Human Rights. The practical effect of this expansion allows CPAs to satisfy two separate requirements (CPE and employer-provided training) imposed by two different public acts with two separate standards with one training as long as that training conforms to the standards of the Illinois Human Rights Act.
Licensees will still have the option to complete CPE provided by a licensed CPE provider or an IDFPR-approved continuing education provider. According to Section 1130.400(b)(1)
of Administrative Procedures for General Professional Regulation Under the Administrative Code, approved providers include an entity recognized under any licensing act; a state, federal, or local government agency; an accredited community college or university; or a licensed health care institution.
If you have multiple IDFPR-issued licenses, you don’t have to repeat the course for each license—the one course can be applied to any licenses you hold. Registered CPAs don’t have a CPE requirement and therefore don’t have to complete sexual harassment prevention training as a part of the license renewal process. However, registered CPAs may still be required to complete employer-provided annual sexual harassment prevention training.
I understand this is a deep dive into licensure compliance issues on the close of a particularly challenging and protracted license renewal process. For citation on the CPE convergence issues, you can reference a technical regulatory bulletin on our ICPAS Government Relations webpage
With regards to the upcoming 2024 CPA license renewal period, we continue to work with the IDFPR’s staff and leadership to identify and alleviate the cascading effects of the new renewal process. While there were many hurdles and frustrations this past renewal cycle, the IT systems continue to be improved and technical issues remedied, laying the groundwork for a smoother 2024 renewal cycle.