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 - An individual whose principal place of business is not in Illinois shall have all the privileges of a person licensed under the Illinois Public Accounting Act (Act) as a CPA without the need to obtain a license from the Illinois Department of Financial and Professional Regulation (IDFPR) or to file notice with the IDFPR, if the individual:
- Notwithstanding any other provision of Illinois law, an individual or CPA firm who offers or renders professional services under this section, whether in person or by mail, telephone, or electronic means, shall be granted practice privileges in Illinois and no notice or other submission must be provided by any such individual or CPA firm.
- An individual licensee who qualifies for practice privileges who performs the following services for any entity headquartered in Illinois may only do so through a CPA firm licensed under this Act or a CPA firm with practice privileges:
- a financial statement audit or other engagement in accordance with Statements on Auditing Standards (SAS);
- an examination of prospective financial information in accordance with Statements on Standards for Attestation Engagements (SSAE); or
- an engagement in accordance with Public Company Accounting Oversight Board Auditing (PCAOB) Standards.
See 225 Ill. Comp. Stat. § 450/5.2 (a, b, & d)
Firm Practice Privilege/Firm Registration Requirement - A CPA firm whose principal place of business is not in Illinois shall have all the privileges of a CPA firm licensed under this Act without the need to obtain a license from the IDFPR or to file notice with the IDFPR if the CPA firm complies with the requirements outlined in 225 Ill. Comp. Stat. § 450/14.4 (Firm Ownership), and 225 Ill. Comp. Stat. § 450/16 (Continuing Education and Peer Review) through enhanced mobility of the firm's licensed state.
- Notwithstanding any other provision of Illinois law, an individual or CPA firm who offers or renders professional services under this section, whether in person or by mail, telephone, or electronic means, shall be granted practice privileges in Illinois and no notice or other submission must be provided by any such individual or CPA firm.
- A CPA firm that qualifies for practice privileges and performs the following services for any entity headquartered in Illinois may only do so through an individual or individuals licensed under this Act, or an individual(s) with practice privileges:
- a financial statement audit or other engagement in accordance with the SAS;
- an examination of prospective financial information in accordance with the SSAE; or
- an engagement in accordance with PCAOB auditing standards.
- Persons, either individually, as members of a partnership, or as officers of a corporation, who sign, affix, or associate names or any trade or assumed names used by the persons in a profession or business to any report expressing or disclaiming an opinion on a financial statement based on an audit or examination of that statement, or expressing assurance on a financial statement, shall be deemed to be in practice as licensed CPAs and are performing accountancy activities as outlined in 225 Ill. Comp. Stat. § 450/8.05(a)(1).
- A CPA firm must hold a license as a CPA firm issued under this Act if it:
- has an office in Illinois that uses the title "CPA" or "CPA firm";
- has an office in Illinois that performs accountancy activities as defined below; or
- does not have an office in Illinois and does not meet the practice privilege requirements as defined below, but offers or renders services, as per 225 Ill. Comp. Stat. § 450/5.2(e), for a client that is headquartered in Illinois;
- A CPA firm that is not subject to the requirements of 225 Ill. Comp. Stat. § 450/13(b) may perform professional services that are not regulated under 225 Ill. Comp. Stat. § 450/13(b) while using the title "CPA" or "CPA firm" in Illinois without obtaining a license as a CPA firm under this Act if the firm:
- performs such services through individuals with practice privileges; and
- may lawfully perform such services in the state where the individuals with practice privileges have their principal place of business.
See 225 Ill. Comp. Stat. § 450/5.2(a-5, b, and e), § 450/8, and § 450/13(b and d)
Qualifications for Registration as a CPA Firm The IDFPR may license as licensed CPA firms individuals or entities meeting the following requirements: - A majority of the ownership of the firm, in terms of financial interests and voting rights of all partners, officers, shareholders, or members, belongs to persons licensed or registered in some state. All partners, officers, shareholders, or members, whose principal place of business is in Illinois and who have overall responsibility for accountancy activities in Illinois, as defined below, must hold a valid license as a licensed CPA issued by Illinois. An individual exercising practice privileges who performs services for which a firm license is required under 225 Ill. Comp. Stat. § 450/5.2(d) shall not be required to obtain an individual license under this Act.
- All owners of the CPA firm, whether licensed as a licensed CPA or not, shall be active participants in the CPA firm or its affiliated entities and shall comply with the rules adopted under this Act.
- It shall be lawful for a nonprofit cooperative association engaged in rendering an auditing and accounting service to its members only to continue to render that service provided that the rendering of an auditing and accounting service by the cooperative association shall at all times be under the control and supervision of licensed CPAs.
- An individual who supervises services which a license is required under 225 Ill. Comp. Stat. § 450/8.05(a)(1), who signs or authorizes another to sign any report for which a license is required under 225 Ill. Comp. Stat. § 450/8.05(a)(1), or who supervises services for which a CPA firm license is required under 225 Ill. Comp. Stat. § 450/5.2(d) shall hold a valid, active CPA license from Illinois or another state considered to be substantially equivalent under 225 Ill. Comp. Stat. § 450/5.2(a)(1).
- The CPA firm shall designate to the IDFPR in writing an individual licensed as a licensed CPA under this Act or, in the case of a firm that must have a CPA firm license pursuant to 225 Ill. Comp. Stat. § 450/13(b), a licensee of another state who meets the requirements of 225 Ill. Comp. Stat. § 450/5.2(a)(1 or 2), who shall be responsible for the proper licensure of the CPA firm.
See 225 Ill. Comp. Stat. § 450/14.4
Consent to Jurisdiction An individual licensee or CPA firm of another state exercising practice privileges, and the CPA firm that employs such individual licensee, if any, as a condition of the grant of this privilege, hereby simultaneously consents: - to the personal and subject matter jurisdiction and disciplinary authority of the IDFPR;
- to comply with this Act and the IDFPR's rules adopted under this Act;
- that in the event that the license from the state of the individual's or CPA firm's principal place of business is no longer valid, the individual or CPA firm shall cease offering or rendering accountancy activities, as defined below, in Illinois individually or on behalf of a CPA firm; and
- to the appointment of the state board that issued the individual's or the CPA firm's license as the agent upon which process may be served in any action or proceeding by the IDFPR against the individual or CPA firm.
See 225 Ill. Comp. Stat. § 450/5.2(c) and § 450/20.01
Peer Review Requirement N/A
Additional Requirements An individual licensee who qualifies for practice privileges who performs the following services for any entity headquartered in Illinois may only do so through a CPA firm licensed under this Act or a CPA firm with practice privileges: - a financial statement audit or other engagement in accordance with the SAS;
- an examination of prospective financial information in accordance with the SSAE; or
- an engagement in accordance with PCAOB Auditing Standards.
See 225 Ill. Comp. Stat. § 450/5.2(d)
Restrictions N/A
Definitions - "Accountancy activities" are services performed by a CPA, including:
- signing, affixing, or associating the names used by a person or CPA firm to any report expressing an assurance on a financial statement or disclaiming an opinion on a financial statement based on an audit or examination of that statement or to express assurance on a financial statement (If offering or performing these accountancy activities using the CPA title, these activities may only be performed by licensed CPAs);
- other attestation engagements not otherwise defined above (If offering or performing accountancy activities using the CPA title, these activities may only be performed by licensed or registered CPAs); or
- offering to perform or performing one or more types of the following services involving the use of professional skills or competencies: accounting, management, financial or consulting services, compilations, internal audit, preparation of tax returns, furnishing advice on tax matters, bookkeeping, or representations of taxpayers; this includes the teaching of any of these areas at the college or university level (If offering or performing accountancy activities using the CPA title, these activities are not restricted to licensed or registered CPAs, subject to the provisions of 225 Ill. Comp. Stat. § 450/9).
- "Compilation" means providing a service to be performed in accordance with Statements on Standards for Accounting and Review Services (SSARS) that is presented in the form of financial statements or information that is the representation of management or owners without undertaking to express any assurance on the statements.
- "CPA firm" means a sole proprietorship, corporation, registered limited liability partnership, professional limited liability company, partnership, professional service corporation, or any other form of organization issued a license in accordance with this Act or a CPA firm authorized to use the CPA firm title under 225 Ill. Comp. Stat. § 450/5.2.
- "Financial statement" means a structured presentation of historical financial information, including, but not limited to, related notes intended to communicate an entity's economic resources and obligations at a point in time or the changes therein for a period of time in accordance with Generally Accepted Accounting Principles (GAAP) or Other Comprehensive Basis of Accounting (OCBOA).
- "Report", when used with reference to financial statements, means an opinion, report, or other form of language that states or implies assurance as to the reliability of any financial statements and that also includes or is accompanied by any statement or implication that the person or firm issuing it has special knowledge or competence in accounting or auditing. Such a statement or implication of special knowledge or competence may arise from use by the issuer of the report of names or titles indicating that the person or firm is an accountant or auditor, or from the language of the report itself. "Report" includes any form of language that disclaims an opinion when the form of language is conventionally understood to imply any positive assurance as to the reliability of the financial statements referred to or special competence on the part of the person or firm issuing such language; it includes any other form of language that is conventionally understood to imply such assurance or such special knowledge or competence.
- "Principal place of business" means the office location designated by the licensee from which the person directs, controls, and coordinates one's professional services.
See 225 Ill. Comp. Stat. § 450/8.05 and § 450/0.03
Statute and/or Regulation References 225 Ill. Comp. Stat. § 450/0.03; § 450/5.2; § 450/8; § 450/13; § 450/14.4; and § 450/20.01
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. |
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