CPA Mobility: Meeting Change With Confidence

In 2025, Gov. J.B. Pritzker signed House Bill 2459 into law, amending the Illinois Public Accounting Act to establish two additional certified public accountant (CPA) licensure pathways. Beginning Jan. 1, 2027, candidates may qualify for licensure by:

• Earning a bachelor’s degree with an accounting concentration, completing at least two years of relevant work experience, and passing the CPA exam.
• Earning a master’s degree with an accounting concentration, completing at least one year of relevant work experience, and passing the CPA exam.

The legislation also preserves Illinois’ existing pathway requiring 150 credit hours of qualifying education, one year of relevant work experience, and passing the CPA exam.

While this change opens exciting opportunities for future CPAs in Illinois, it adds a new layer of complexity and uncertainty for licensees and CPA firms. Nearly half the states across the country have adopted similar alternative pathways, while others are still evaluating changes to their licensure models. This uneven adoption has implications for CPA mobility and interstate practice.

“We’re in a time of transition,” acknowledges James Cox, vice president of state advocacy and state society relations at the AICPA and CIMA. Because of this, he encourages CPAs and CPA firms to take a long-term perspective as state legislatures continue evaluating licensure reforms.

WHY MAINTAINING CPA MOBILITY MATTERS

CPA mobility is intended to reflect the modern realities of accounting practice where firms, clients, and engagement teams frequently operate across multiple jurisdictions.

The CPA mobility system was built on the concept of substantial equivalency, allowing states to recognize each other’s licensure requirements as comparable. CPAs can serve clients across state lines without obtaining additional licenses provided they meet uniform education, examination, and experience standards.

“CPAs enjoy an incredible amount of cross-border practice privileges—much more so than other licensed professions like lawyers and doctors,” says Julia Woislaw, vice president of strategic partnerships and regulatory affairs at CPA QualityPro, a cloud-based software solution that automates and streamlines CPA firm license registrations, renewals, and mobility compliance tracking.

Yet, despite these privileges, Woislaw says there are challenges and risks to mobility at play: “It’s tricky right now because some states have changed their licensure laws while others haven’t. As a result, state boards could begin questioning whether certain licenses remain substantially equivalent, which could disrupt interstate practice.”

Marty Green, Esq., senior vice president and legislative counsel at the Illinois CPA Society, adds that legislative activity has added to the uncertainty: “CPAs have become comfortable with mobility, and many don’t realize how much has changed across jurisdictions in the last year.” As regulatory frameworks shift, understanding the difference between mobility and reciprocity is important.

• Mobility: Allows CPAs to temporarily practice across state lines using their home state license without obtaining an additional license.
• Reciprocity: Requires CPAs to apply for and obtain licensure in another state, typically when establishing a physical presence, opening an office, or permanently practicing there.

The two terms are often used interchangeably, but Cox stresses they shouldn’t be: “Those are two different concepts. Mobility was designed to reduce the burden of maintaining multiple licenses, which is why maintaining it is so important.”

WHERE MOBILITY RISKS MAY ARISE

As new pathways legislation evolves across the country, mobility eligibility will increasingly depend on how a CPA originally qualified for licensure. CPAs licensed under the traditional 150 credit-hour education model are expected to maintain broad mobility privileges. However, CPAs licensed under newer pathways may encounter challenges when practicing in states that haven’t yet adopted similar licensure changes.

“If states don’t adopt comparable pathways, CPAs and CPA firms could run into issues,” Cox explains. “That’s where practitioners need to be especially cautious.”

Woislaw adds that state boards of accountancy may begin taking a closer look at licensure qualifications during reviews or investigations: “Questions that never surfaced before may now become part of regulatory oversight. Will an audit report be called into question, or will a firm have a deficiency on a peer review, because suddenly a CPA didn’t meet the rules in another state? These are questions we don’t know the answer to yet.”

Of course, as these uncertainties play out, Woislaw cautions that failure to comply with these licensure requirements could expose CPAs and CPA firms to disciplinary actions, fines, or complications during their peer review or audit oversight.

CPA MOBILITY TRANSITION CHECKLIST: PRACTICAL STEPS FOR FIRMS AND LICENSEES

During this period of regulatory change, proactive compliance planning is essential. Experts recommend implementing the following steps to evaluate mobility eligibility and reduce risk.

Verify Eligibility Before Accepting Cross-State Engagements

Before performing work in another jurisdiction, CPAs should confirm that their home state license satisfies the destination state’s mobility requirements. This includes reviewing each state’s accountancy laws and regulations, particularly provisions related to:

• Individual licensure requirements.
• Firm ownership rules.
• Firm registration obligations.
• Peer review standards.

“CPAs know how to perform due diligence,” Green says. “They should apply that same discipline to their professional licensure requirements.”

Maintain Comprehensive Licensure Documentation

Firms should track and maintain detailed licensure records for all CPAs, including:

• Education pathway completed (i.e., 120 or 150 credit hours).
• Degree earned and accounting concentration.
• Length and type of qualifying experience.
• Verification or supervision of experience.

“These are the guardrails states use to determine mobility eligibility,” Woislaw explains.

Monitor Regulatory Developments Across Jurisdictions

State laws, state boards of accountancy rules, policy statements, and regulatory guidance will happen in stages. Therefore, firms should regularly review:

• Administrative rulemaking updates.
• State boards of accountancy newsletters and announcements.
• State CPA society updates.

“Monitor not only formal rule changes, but also watch for other ways state boards might communicate the information,” Woislaw suggests. “Firms sometimes forget they can contact state boards of accountancy directly, so if questions arise, reach out and ask them.”

BUILDING MOBILITY COMPLIANCE INTO FIRM STRATEGY

While many states are adopting safe harbor provisions to protect CPAs licensed under previous standards and preserve interstate practice rights during regulatory transitions, experts emphasize that mobility compliance should become part of routine client and engagement planning to reduce the likelihood of unintended compliance violations.

“When evaluating new engagements, firms should consider where clients are located and how licensing requirements affect service delivery,” Cox says.

Firms must also recognize that mobility requirements may vary based on service type. For example, signing audit opinions often triggers stricter compliance standards than performing supporting engagement work.

LEVERAGING TECHNOLOGY AND COMPLIANCE TOOLS

Mobility compliance can involve a complex decision tree that varies by firm, individual, and service type. To manage this growing regulatory complexity, firms are increasingly turning to compliance software designed to track licensure data and mobility eligibility across jurisdictions. These platforms can:

• Track firm registrations across states.
• Compare individual licensure qualifications against state mobility standards.
• Identify jurisdictions requiring additional registrations or licensing.
• Provide mobility determinations at both firm and individual levels.

“Technology solutions [like CPA QualityPro] allow firms to analyze mobility from a firmwide perspective while also evaluating individual practitioners,” Woislaw explains.

TURNING UNCERTAINTY INTO OPPORTUNITY

Despite increased complexity, CPA mobility remains a significant professional advantage.

“CPAs have benefited from mobility for many years,” Green says. “It’s worked in Illinois since 2007 for individual CPAs and since 2017 for firms. There’s no reason to panic because things are changing, but there’s reason to prepare.”

Cox encourages firms to treat regulatory change as an opportunity to strengthen compliance infrastructure and better understand their operational footprint: “Evaluate where your firm has clients or physical presence and take stock of your compliance status. This is a valuable opportunity to understand the regulatory environment in which you operate.”

Woislaw agrees and stresses that firms should begin preparing now, particularly as new CPA licensees begin to enter the profession under the new pathways this year.

“This is a confusing time, but the information is available in state statutes and regulatory guidance,” Woislaw says. “Firms should feel empowered to learn the requirements across jurisdictions and develop systems to capture licensure pathway information from the start.”

As CPA licensure rapidly evolves across the country, Woislaw stresses this is the year to get serious about licensure compliance: “Firms that build strong compliance systems now will be better positioned to protect their mobility privileges and continue serving clients wherever they operate.”