Mobility is a practice privilege that generally permits a licensed CPA in good standing to practice in a state from outside of their principal place of business without obtaining another license, so long as the licensee meets certain state specific conditions.
For state accountancy boards that have adopted the Uniform Accountancy Act § 23 Safe Harbor language for mobility, this will allow those licensees who had practice privileges prior to a specific date to proceed to practice, so long as they have a license in good standing and no other state specific restrictions apply. Currently, Delaware, Texas, and Pennsylvania have adopted the UAA Safe Harbor Language for Mobility.
As of January 1, 2026:
Individual Practice Privilege Under BPC § 5096:
- An individual whose principal place of business is not in California and who has a current and active license, certificate, or permit to practice public accountancy from another state may, subject to the conditions and limitations of practice privilege, engage in the practice of public accountancy in California under a practice privilege without obtaining a certificate or license under BPC Chapter 1. Accountants.
- An individual who qualifies for practice privilege may engage in the practice of public accountancy in California, and a notice, fee, or other requirement shall not be imposed on that individual by the California Board of Accountancy (CBA).
- An individual who qualifies for practice privilege may perform the following services only through a firm of certified public accountants that has obtained a registration from the CBA pursuant to BPC § 5096.12:
- An audit or review of a financial statement for an entity headquartered in California.
- A compilation of a financial statement when that person expects, or reasonably might expect, that a third party will use the financial statement and the compilation report does not disclose a lack of independence for an entity headquartered in California.
- An examination of prospective financial information for an entity headquartered in California.
See also 16 CCR § 19.
Under BPC § 5088: - Any individual who is the holder of a current, active, and unrestricted license as a certified public accountant issued under the laws of any state and who applies to the CBA for a license as a certified public accountant under the provisions of BPC § 5087 may, until the time the application for a license is granted or denied, practice public accountancy in California only under a practice privilege pursuant to the provisions of Article 5.1 (commencing with BPC § 5096), except that, for purposes of practice privilege, the individual is not disqualified from a practice privilege during the period the application is pending by virtue of maintaining an office or principal place of business, or both, in California. The CBA may by regulation provide for exemption, credit, or proration of fees to avoid duplication of fees
Firm Practice Privilege/Firm Registration Requirement Under BPC § 5096.12.: - A certified public accounting firm that is authorized to practice in another state and that does not have an office in California may engage in the practice of public accountancy in California through the holder of a practice privilege provided that:
- The CBA may revoke, suspend, issue a fine pursuant to Article 6.5 (commencing with Section 5116 CA Business and Professions Code), issue a citation and fine pursuant to BPC § 125.9, or otherwise restrict or discipline the firm for any act that would be grounds for discipline against a holder of a practice privilege through which the firm practices.
- A firm that provides the services described in BPC § 5096(c) shall obtain a registration from the CBA. At the time of registration, if the firm has a valid email address, it shall provide that email address to the CBA. Those services include:
An audit or review of a financial statement for an entity headquartered in California. A compilation of a financial statement when that person expects, or reasonably might expect, that a third party will use the financial statement and the compilation report does not disclose a lack of independence for an entity headquartered in California. An examination of prospective financial information for an entity headquartered in California.
See also 16 CCR § 20.
Consent to Jurisdiction Under BPC § 5096(d):
- An individual who holds a practice privilege under this article, and is exercising the practice privilege in California:
- Is subject to the personal and subject matter jurisdiction and disciplinary authority of the CBA and the courts of California.
- Shall comply with the provisions of the CBA regulations, and other laws, regulations, and professional standards applicable to the practice of public accountancy by the licensees of California and to any other laws and regulations applicable to individuals practicing under practice privileges in California, except the individual is deemed, solely for the purpose of this article, to have met the continuing education requirements of California when the individual has met the continuing education requirements of the state in which the individual holds the current and active license, certificate, or permit.
- Shall not provide public accountancy services in California from any office located in California, except as an employee of a firm registered in California. This paragraph does not apply to public accountancy services provided to a client at the client’s place of business or residence.
- Is deemed to have appointed the regulatory agency of the state in which the principal place of business identified by the individual is located, as the individual’s agent on whom notices, subpoenas, or other process may be served in any action or proceeding by the CBA against the individual.
- Shall cooperate with any CBA investigation or inquiry and shall timely respond to a CBA investigation, inquiry, request, notice, demand, or subpoena for information or documents and timely provide to the CBA the identified information and documents.
- Shall cease exercising the practice privilege in California if a regulatory agency in a state in which the individual holds a certificate, license, or permit takes disciplinary action resulting in the suspension or revocation, including stayed suspension, stayed revocation, or probation of the individual’s certificate, license, or permit, or takes other disciplinary action against the individual’s certificate, license, or permit that arises from any of the following:
- Gross negligence, recklessness, or intentional wrongdoing relating to the practice of public accountancy.
- Fraud or misappropriation of funds.
- Preparation, publication, or dissemination of false, fraudulent, or materially incomplete or misleading financial statements, reports, or information.
- Shall cease exercising the practice privilege in California if convicted in any jurisdiction of any crime involving dishonesty, including, but not limited to, embezzlement, theft, misappropriation of funds or property, or obtaining money, property, or other valuable consideration by fraudulent means or false pretenses.
- Shall cease exercising the practice privilege if the United States Securities and Exchange Commission (SEC) or the Public Company Accounting Oversight Board (PCAOB) bars the individual from practicing before them.
- Shall cease exercising the practice privilege if any governmental body or agency suspends the right of the individual to practice before the body or agency.
- Shall report to the CBA in writing any pending criminal charges, other than for a minor traffic violation, in any jurisdiction within thirty (30) days of the date the individual has knowledge of those charges.
- An individual who is required to cease practice pursuant to sub-bullet points six (6) to nine (9) above, inclusive, shall notify the CBA within fifteen (15) calendar days, on a form prescribed by the CBA, and shall not practice public accountancy in California pursuant to this section until the individual has received from the CBA written permission to do so.
- An individual who fails to cease practice as required by BPC § 5096(d) or who fails to provide the notice required by BPC § 5096(e) shall be subject to the personal and subject matter jurisdiction and disciplinary authority of the CBA as if the practice privilege were a license and the individual were a licensee. An individual in violation of BPC § 5096(d) or (e) shall, for a minimum of one (1) year from the date the CBA learns there has been a violation of BPC § 5096(d) or (e), not practice in California and shall not have the possibility of reinstatement during that period. If the CBA determines that the failure to cease practice or provide the notice was intentional, that individual’s practice privilege shall be revoked and there shall be no possibility of reinstatement for a minimum of two (2) years.
- The CBA shall require an individual who provides notice to the CBA pursuant to BPC § 5096(e) to cease the practice of public accountancy in California until the CBA provides the individual with written permission to resume the practice of public accountancy in California.
- An individual to whom, within the last seven (7) years immediately preceding the date on which the individual wishes to practice in California, any of the following criteria apply, shall notify the CBA, on a form prescribed by the CBA, and shall not practice public accountancy in California pursuant to this section until the CBA provides the individual with written permission to do so:
- The individual has been the subject of any final disciplinary action by the licensing or disciplinary authority of any other jurisdiction with respect to any professional license or has any charges of professional misconduct pending against that individual in any other jurisdiction.
- The individual has had their license in another jurisdiction reinstated after a suspension or revocation of the license.
- The individual has been denied issuance or renewal of a professional license or certificate in any other jurisdiction for any reason other than an inadvertent administrative error.
- The individual has been convicted of a crime or is subject to pending criminal charges in any jurisdiction other than a minor traffic violation.
- The individual has otherwise acquired a disqualifying condition as described in BPC § 5096.2(a).
- An individual who fails to cease practice as required by BPC § 5096(d) or who fails to provide the notice required by bullet two (2) above shall be subject to the personal and subject matter jurisdiction and disciplinary authority of the CBA as if the practice privilege were a license and the individual were a licensee. An individual in violation of BPC § 5096(d)(1) shall, for a minimum of one (1) year from the date the CBA knows there has been a violation of BPC § 5096(d) or BPC § 5096(d)(1), not practice in California and shall not have the possibility of reinstatement during that period. If the CBA determines that the failure to cease practice or provide the notice was intentional, that individual shall be prohibited from practicing in California in the same manner as if a licensee has that licensee’s practice privilege revoked and there shall be no possibility of reinstatement for a minimum of two (2) years.
- At the time of notification pursuant to BPC § 5096(e) or (h), if the individual has a valid email address, that individual shall provide that email address to the CBA.
- The CBA shall consult the PCAOB and the United States SEC at least once every six (6) months to identify out-of-state licensees who may have disqualifying conditions or who may be obliged to cease practice, and shall disclose, pursuant to this subdivision, whether those out-of-state licensees are lawfully permitted to exercise the privilege. Disclosure of this information shall not be considered discipline.
Under BPC § 5096.12.:
- A certified public accounting firm that is authorized to practice in another state and that does not have an office in California may engage in the practice of public accountancy in California through the holder of a practice privilege provided that:
- The practice of public accountancy by the firm is limited to authorized practice by the holder of the practice privilege.
- A firm that engages in practice under this section is deemed to consent to the personal, subject matter, and disciplinary jurisdiction of the CBA with respect to any practice under this section.
- The CBA may revoke, suspend, issue a fine pursuant to Article 6.5 (commencing with Section 5116 CA Business and Professions Code), issue a citation and fine pursuant to BPC § 125.9, or otherwise restrict or discipline the firm for any act that would be grounds for discipline against a holder of a practice privilege through which the firm practices.
See also 16 CCR § 20.
Peer Review Requirement Under 16 CCR § 40:
- A firm performing services as defined in 16 CCR § 39(a) shall have a peer review report accepted by a CBA-recognized peer review program once every three (3) years in order to renew its license.
- A firm performing services as defined in 16 CCR § 39(a) for the first time shall have a peer review report accepted by a CBA-recognized peer review program within eighteen (18) months of the date it completes those services.
Under 16 CCR § 42:
- The following shall be excluded from the peer review requirement:
- Any of a firm's engagements subject to inspection by the PCAOB as part of its inspection program.
- Firms, which as their highest level of work, perform only preparation engagements (with or without disclaimer reports) in accordance with the provisions of the Statements on Standards for Accounting and Review Services (SSARS).
Additional Requirements Under BPC § 5095:
- To be authorized to sign reports on attest engagements, a licensee shall complete a minimum of five hundred (500) hours of experience, satisfactory to the CBA, in attest services. The CBA may, by regulation, also require the completion of specified job tasks associated with performing attest services.
- To qualify for practice privilege, verified attest experience shall have been performed in accordance with applicable professional standards. Experience in public accounting shall be completed under the supervision or in the employ of a person licensed or otherwise having comparable authority under the laws of any state or country to engage in the practice of public accountancy and provide attest services.
- Experience outside of public accounting shall be completed under the supervision of an individual licensed by a state to engage in the practice of public accountancy and perform attest services.
- An applicant may be required to present work papers or other evidence substantiating that the applicant has met the requirements of this section and any applicable regulations.
- The CBA shall adopt regulations to implement this section, including, but not limited to, a procedure for applicants under BPC § 5093 to qualify under this section.
See also 16 CCR § 12.5 and 16 CCR § 50.1.
Under BPC § 5096.20:
- To ensure that Californians are protected from out-of-state licensees with disqualifying conditions, the CBA shall maintain an out-of-state licensee feature on its license lookup tab of the home page of its internet website that allows consumers to obtain information about an individual whose principal place of business is not in California and who seeks to exercise a practice privilege in California. At minimum, these features shall include all of the following:
- The ability of the consumer to search by name and state of licensure.
- The disclosure of information in the possession of the CBA, which the CBA is otherwise authorized to publicly disclose, about an individual exercising a practice privilege in California, including, but not limited to, whether the CBA has taken action of any form against that individual and, if so, what the action was or is.
- A disclaimer that the consumer must click through prior to being referred to any other internet website, which in plain language explains that the consumer is being referred to an internet website that is maintained by a regulatory agency or other entity that is not affiliated with the CBA. This disclaimer shall include a link to relevant sections of this article that set forth disqualifying conditions, including, but not limited to, BPC § 5096.2.
- A statement in plain language that notifies consumers that they are permitted to file complaints against such individuals with the CBA.
- A link to the internet website or sites that the CBA determines, in its discretion, provides the consumer the most complete and reliable information available about the individual’s status as a licenseholder, permit holder, or certificate holder.
- If the board of another state does not maintain an internet website that allows a consumer to obtain information about its licensees including, but not limited to, disciplinary history, and that information is not available through a link to an internet website maintained by another entity, a link to contact information for that board, which contains a disclaimer in plain language that explains that the consumer is being referred to a board that does not permit the consumer to obtain information, including, but not limited to, disciplinary history, about individuals through the internet website, and that the out-of-state board is not affiliated with the CBA.
- The CBA shall biennially survey the internet websites and disclosure policies of other boards to ensure that its disclaimers are accurate.
Under BPC § 5096.21:
- If the CBA determines, through a majority vote of the CBA at a regularly scheduled meeting, that allowing individuals from a particular state to practice in California pursuant to a practice privilege as described in BPC § 5096, violates the CBA’s duty to protect the public, pursuant to BPC § 5000.1, the CBA shall require out-of-state individuals licensed from that state, as a condition to exercising a practice privilege in California, to file the notification form and pay the applicable fees as required by BPC § 5096.22.
- A state for which the CBA has made a determination pursuant to the above bullet point to require individuals licensed from that state to file a notification form and pay the applicable fees may subsequently be redetermined by the CBA, by majority vote of the CBA at a regularly scheduled meeting, to allow individuals from that state to practice in California pursuant to a practice privilege as described in BPC § 5096.
- The CBA shall, at minimum, consider the following factors when making a determination or re-determination pursuant to BPC § 5096(a):
- Whether the state timely and adequately addresses enforcement referrals made by the CBA to the accountancy regulatory board of that state, or otherwise fails to respond to requests the CBA deems necessary to meet its obligations under this article.
- Whether the state makes the disciplinary history of its licensees publicly available through the internet in a manner that allows the CBA to adequately link consumers to an internet website to obtain information.
- Whether the state imposes discipline against licensees that is appropriate in light of the nature of the alleged misconduct.
- Whether the state has in place and is operating pursuant to enforcement practices substantially equivalent to the current best practices guidelines adopted by the National Association of State Boards of Accountancy (NASBA) provided those guidelines have been determined by the CBA to meet or exceed the CBA’s own enforcement practices.
- Whether the state has in place and implements comparable licensure requirements.
Under BPC § 5096.22:
- An individual whose principal place of business is in a state subject to an action of the CBA pursuant to BPC § 5096.21 shall do all of the following:
- Prior to practicing, submit a notification form to the CBA in a manner prescribed by CBA regulation.
- If the CBA has determined the state in which the individual has their principal place of business to not have comparable licensure requirements, indicate on the notification form they satisfy one (1) of the following:
- Have continually practiced public accountancy as a certified public accountant under a current and active license issued by any state for at least four (4) of the last ten (10) years.
- Have passed the Uniform Certified Public Accountant Examination and completed education that included a baccalaureate degree or higher with an accounting concentration and at least one (1) year of general accounting experience.
- Pay a fee equal to the reasonable administrative costs, as established by the CBA.
- Except as otherwise provided by this article or by CBA regulation, a practice privilege subject to this section shall commence when the individual submits a properly completed notification form to the CBA, provided that the fee is received by the CBA within thirty (30) days of that date. The CBA shall permit the notification to be provided electronically.
- An individual shall not be deemed to be in violation of this section solely because they begin the practice of public accounting in California prior to notifying the CBA as indicated above, provided the notice is given within five (5) business days of the date practice begins. An individual who properly notifies the CBA within the five-day (5-day) period provided for in this subdivision shall be deemed to have a practice privilege from the first day of practice in California unless the individual fails to timely submit the required fee. Failure to comply with this section means that the individual is practicing public accountancy unlawfully in California and is in violation of BPC § 5120. In addition to any other available remedy, the CBA may issue a fine equal to reasonable enforcement costs if an individual notifies the CBA more than five (5) business days after beginning practice in California.
- An individual whose principal place of business is in a state subject to an action by the CBA pursuant to BPC § 5096.21 shall not be deemed in violation of the notice and fee requirements of this section if the failure to comply occurs within sixty (60) days of the date of the CBA action.
Restrictions Under BPC § 5096(d)(3):
- An individual who holds a practice privilege, and is exercising the practice privilege in California:
- Shall not provide public accountancy services in California from any office located in California, except as an employee of a firm registered in California. This paragraph does not apply to public accountancy services provided to a client at the client’s place of business or residence.
Under BPC § 5096.1:
- Any individual, not a licensee of California, who is engaged in any act which is the practice of public accountancy in California, and who does not qualify to practice pursuant to the practice privilege described in BPC § 5096 and who has a license, certificate, or other authority to engage in the practice of public accountancy in any other state, regardless of whether active, inactive, suspended, or subject to renewal on payment of a fee or completion of an educational or ethics requirement, is:
- Deemed to be practicing public accountancy unlawfully in California.
- Subject to the personal and subject matter jurisdiction and disciplinary authority of the CBA and the courts of California to the same extent as a holder of a valid practice privilege.
- Deemed to have appointed the regulatory agency of the state in which the principal place of business identified by the individual is located, as the individual’s agent on whom notices, subpoenas, or other process may be served in any action or proceeding by the CBA against the individual.
- The CBA may revoke a practice privilege from any individual who has violated this section or implementing regulations or committed any act which would be grounds for discipline against the holder of a practice privilege.
Under BPC § 5096.4:
- The right of an individual to practice in California under a practice privilege may be administratively suspended at any time by an order issued by the CBA or its executive officer, without prior notice or hearing, for the purpose of conducting a disciplinary investigation, proceeding, or inquiry concerning the individual’s competence or qualifications to practice under practice privileges, failure to timely respond to a CBA inquiry or request for information or documents, or under other conditions and circumstances provided for by CBA regulation.
- The administrative suspension order is immediately effective when mailed to the individual’s address of record or agent for notice and service as provided for in this article.
- The administrative suspension order shall contain the following:
- The reason for the suspension.
- A statement that the individual has the right, within thirty (30) days, to appeal the administrative suspension order and request a hearing.
- A statement that any appeal hearing will be conducted under the provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code) applicable to individuals who are denied licensure, including the filing of a statement of issues by the CBA setting forth the reasons for the administrative suspension of practice privileges and specifying the statutes and rules with which the individual must show compliance by producing proof at the hearing and in addition any particular matters that have come to the attention of the CBA and that would authorize the administrative suspension, or the revocation of practice privileges.
- The burden is on the holder of the suspended practice privilege to establish both qualification and fitness to practice under practice privileges.
- The administrative suspension shall continue in effect until terminated by an order of the CBA or the executive officer.
- Administrative suspension is not discipline and shall not preclude any individual from applying for a license to practice public accountancy in California.
- Proceedings to appeal an administrative suspension order may be combined or coordinated with proceedings for revocation or discipline of a practice privilege.
Definitions Under BPC §5030 - §5040; 16 CCR § 1
- “Attest services” as used in BPC § 5095 and “Attest Report” as used in BPC § 5096.5 include an audit, a review of financial statements, or an examination of prospective financial information. Attest services shall not include the issuance of compiled financial statements.
- “Comparable licensure requirements” means another state requires passage of the examination described in BPC § 5082 and has education and experience requirements, when considered collectively, that meet or exceed the standards established by the CBA pursuant to Article 5 (commencing with Section 5080).
- “Firm” means a sole proprietorship, a corporation, or a partnership. For purposes of BPC § 5054 and BPC § 5096.12., “firm” includes any entity that is authorized or permitted to practice public accountancy as a firm under the laws of another state.
- “Person” includes individual, partnership, firm, association, limited liability company, or corporation, unless otherwise provided.
Statute and/or Regulation Reference BPC § 5030 - § 5040
BPC § 5088
BPC § 5095
BPC § 5096
16 CCR § 2
16 CCR § 12.5
16 CCR § 19
16 CCR § 20
16 CCR § 50.1
Disclaimer: The information contained in NASBA’s Accountancy Licensing Library and CPAmobility.org is for informational purposes only and should not be construed as legal advice or legal opinion. The information is based on current state board of accountancy law and rules which are publicly available. Because board law and rules are continuously changing, there may be a slight delay in law or rule effective dates and the information reflected in these websites. NASBA cannot guarantee a mobility outcome based solely on the information contained in these websites, as additional state factors not listed here may be applicable. It is the responsibility of each CPA licensee or permit holder to be knowledgeable of each state board's current laws and rules in the state(s) in which the licensee intends to practice via mobility.
Click Reciprocal Licensure and/or Firm Registration in the menu bar at the top of this page for additional information or if these practice privilege requirements do not apply to you or your firm. |
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