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 May 24, 2025:
Individual Practice Privilege - An individual whose principal place of business is not in Minnesota shall be presumed to have qualifications substantially equivalent to Minnesota requirements and shall have all the privileges of Minnesota licensees without the need to obtain a license if the person:
- holds a valid certificate, license, or permit to practice as a CPA that was issued in another state and is in good standing to practice as a CPA in that state;
- has a bachelor's degree or higher from an accredited post-secondary school with an accounting concentration or equivalent as determined by the Minnesota Board of Accountancy by rule; and
- has passed the Uniform CPA Examination.
- Notwithstanding any contrary provision of this chapter, an individual who offers or renders professional services, whether in person, by mail, telephone, or electronic means, under Minnesota Practice Privileges shall be granted practice privileges in Minnesota; is subject to the consent to jurisdiction requirements; and is not required to provide any notice or other submission.
See Minn. Stat. § 326A.14
Firm Practice Privilege/Firm Registration Requirement - An individual who has been granted practice privileges under Minn. Stat. § 326A.14 who performs the following attest services as defined in Minn. Stat. § 326A.01(2), (1), (4), or (5), for any entity with its headquarters in Minnesota, may only do so through a firm which has obtained a permit under Minn. Stat. § 326A.05:
- an audit or other engagement performed in accordance with the Statements on Auditing Standards (SAS);
- an examination of prospective financial information performed in accordance with the Statements on Standards for Attestation Engagements (SSAE); or
- an engagement performed in accordance with the standards of the Public Company Accounting Oversight Board (PCAOB).
- A firm possessing a valid permit from another state which does not have an office in Minnesota may perform the following services:
- an audit or other engagement performed in accordance with the Generally Accepted Government Auditing Standards (GAGAS);
- an engagement performed in accordance with the standards of the PCAOB;
- a "Compilation" meaning the provision of a service performed in accordance with Statements on Standards for Accounting and Review Services (SSARS) that presents in the form of financial statements information that is the representation of management or owners without undertaking to express any assurance on the statements.
for a client having its headquarters in Minnesota and may use the title "CPA" or "CPA firm" without a permit issued under Minn. Stat. § 326A.05 only if: - it has a simple majority of the ownership of the firm, in terms of financial interests and voting rights of all partners, officers, shareholders, members, or managers, must belong to holders of certificates who are licensed in some state, and the partners, officers, shareholders, members, or managers, whose principal place of business is Minnesota, and who perform professional services in Minnesota, must hold valid certificates issued under Minn. Stat. § 326A.04 or the corresponding provision of prior law. Although firms may include non-licensee owners, the firm and its ownership must comply with rules adopted by the Minnesota Board of Accountancy. The firm shall register all non-licensee owners with the Minnesota Board of Accountancy as set forth by rule. An individual who has been granted practice privileges under Minn. Stat. § 326A.14 and who performs services for which a firm permit is required under Minn. Stat. § 326A.14(1)(d) is not required to obtain a certificate from the Minnesota Board of Accountancy under Minn. Stat. § 326A.04;
- as a condition to the renewal of the firm's permit issued by the other state, that state requires a peer review which contains the requirements equivalent to the peer review requirements listed below; and
- it performs the services through an individual who has been granted practice privileges under Minn. Stat. § 326A.14.
- A firm possessing a valid permit from another state that does not have an office in Minnesota and which is not subject to the firm permit requirements of Minn. Stat. § 326A.05(a)(4), or the practice privilege requirements for services performed in Minn. Stat. § 326A.05(b), may perform other professional services while using the title "CPA" or "CPA firm" in Minnesota without a permit issued under Minn. Stat. § 326A.05 only if the firm:
- has a simple majority of the ownership of the firm, in terms of financial interests and voting rights of all partners, officers, shareholders, members, or managers, must belong to holders of certificates who are licensed in some state, and the partners, officers, shareholders, members, or managers, whose principal place of business is in Minnesota, and who perform professional services in Minnesota, must hold valid certificates issued under Minn. Stat. § 326A.04 or the corresponding provision of prior law. Although firms may include non-licensee owners, the firm and its ownership must comply with rules adopted by the Minnesota Board of Accountancy. The firm shall register all non-licensee owners with the Minnesota Board of Accountancy as set forth by rule. An individual who has been granted practice privileges under Minn. Stat. § 326A.14 and who performs services for which a firm permit is required under Minn. Stat. § 326A.14(1)(d), is not required to obtain a certificate from the Minnesota Board of Accountancy under Minn. Stat. § 326A.04;
- performs the services through an individual who has been granted practice privileges under Minn. Stat. § 326A.14; and
- can lawfully perform the services in the state where the individuals with practice privileges have their principal place of business.
See Minn. Stat. § 326A.05
Consent to Jurisdiction - An individual licensee of another state exercising the privilege afforded in Minnesota and the firm which employs that licensee are deemed to have consented, as a condition of the grant of this privilege:
- to the personal and subject matter jurisdiction and disciplinary authority of the Minnesota Board of Accountancy;
- to comply with the Minnesota Accountancy Statute and the Minnesota Board of Accountancy's rules;
- to the appointment of the state board that issued the license as the licensee's agent upon whom process may be served in any action or proceeding by the Minnesota Board of Accountancy against the licensee; and
- to cease offering or rendering professional services in Minnesota individually and on behalf of a firm in the event the license issued by the state of the individual's principal place of business is no longer valid or in good standing.
- A licensee of Minnesota offering or rendering services or using the CPA title in another state is subject to the same disciplinary action in Minnesota for which the licensee would be subject to discipline for an act committed in the other state. The Minnesota Board of Accountancy shall investigate any complaint made by the board of accountancy of another state.
See Minn. Stat. § 326A.14(1)(c) and (2)
Peer Review Requirement - Firms must undergo, no more frequently than once every three (3) years, peer reviews conducted in a manner specified by the Minnesota Board of Accountancy. The review must include a verification that individuals in the firm who are responsible for supervising attest and compilation services and who sign or authorize someone to sign the accountant's report on the financial statements on behalf of the firm meet the competency requirements set out in the professional standards for such services.
- Peer review processes should be operated and documents maintained in a manner designed to preserve confidentiality, and that neither the Minnesota Board of Accountancy nor any third party, other than the oversight body, has access to documents furnished or generated in the course of the review.
See Minn. Stat. § 326A.05(8) and Minn. R. 1105.4800
Additional Requirements N/A
Restrictions - An individual who has been granted practice privileges under Minn. Stat. § 326A.14 who performs the following attest services as defined in Minn. Stat. § 326A.01(2), (1), (4), or (5), for any entity with its headquarters in Minnesota, may only do so through a firm which has obtained a permit under Minn. Stat. § 326A.05:
- an audit or other engagement performed in accordance with the SAS;
- an examination of prospective financial information performed in accordance with the SSAE; or
- an engagement performed in accordance with the standards of the PCAOB.
See Minn. Stat. § 326A.14(1)(d)
Definitions (See Minn. Stat. § 326A.01) - "Attest" in Minnesota means providing any of the following services:
- an audit or other engagement performed in accordance with the SAS;
- an audit or other engagement performed in accordance with the GAGAS;
- a review of a financial statement performed in accordance with the SSARS;
- an examination of prospective financial information performed in accordance with the SSAE;
- an engagement performed in accordance with the standards of the PCAOB; and
- an exam, review, or agreed-upon procedures engagement performed in accordance with SSAE, other than an exam described in the fourth (4th) bullet point above.
- "Compilation" in Minnesota means the provision of a service performed in accordance with SSARS that presents in the form of financial statements information that is the representation of management or owners without undertaking to express any assurance on the statements.
- "CPA firm" means a sole proprietorship, a corporation, a partnership, or any other form of organization issued a permit under Minn. Stat. § 326A.05.
- "Peer review" means an independent study, appraisal, or review of one (1) or more aspects of the professional work of a licensee or CPA firm that issues attest or compilation reports, or the professional work of a person registered under Minn. Stat. § 326A.06(b), by persons who are not affiliated with the licensee or CPA firm being reviewed.
- "Principal place of business" in Minnesota means the office location designated by the licensee for purposes of substantial equivalency and reciprocity.
- "Report," when used with reference to an attest or compilation service, means an opinion, report, or other form of language that states or implies assurance as to the reliability of the attested information or compiled financial statements and that also includes or is accompanied by a 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. The term "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 attested information or compiled financial statements referred to or special competence on the part of the person or firm issuing the language. It includes any other form of language that is conventionally understood to imply such assurance or such special knowledge or competence.
- "Substantial equivalency" is a determination by the Minnesota Board of Accountancy or its designee that the education, exam, and experience requirements contained in another jurisdiction's statutes and rules are comparable to, or exceed the education requirements in Minn. Stat. § 326A.03(3) and (6)(a), exam requirements in Minn. Stat. § 326A.03(4)(a), and experience requirements in Minn. Stat. § 326A.03(6)(b), or that an individual CPA's education, exam, and experience qualifications are comparable to or exceed the education, exam, and experience requirements in this section. For purposes of ascertaining substantial equivalency under the provisions of this chapter, the Minnesota Board of Accountancy shall take into account the qualifications of the individual without regard to the sequence in which experience, education, or exam were attained.
Statute and/or Regulation Reference Minn. Stat. § 326A.01, § 326A.05, § 326A.14, and Minn. R. 1105.4800
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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