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, Alabama, Arizona, Arkansas, Colorado, Connecticut, Delaware, District of Columbia, Idaho, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Nebraska, New Hampshire, New Jersey, Oklahoma, Pennsylvania, Rhode Island, South Dakota, Texas, Vermont, West Virginia, and Wisconsin have adopted the UAA Safe Harbor Language for Mobility.
Effective August 28, 2026:
Individual Practice Privilege (See RSMo § 326.283 and 20 CSR 2010-2.022) - An individual whose principal place of business, domicile, or residency is not in Missouri and who holds a valid and unrestricted license in good standing to practice public accounting from any state shall have all the privileges of a licensee of Missouri without the need to obtain a license or to otherwise notify or register with the Missouri State Board of Accountancy or pay any fee, provided that at the time of initial licensure, the individual was required to show evidence of:
- Having passed the Uniform CPA Examination, and
- Having met one (1) of the following requirements:
- A baccalaureate degree conferred by an accredited college or university, with the total educational program including an accounting concentration or equivalent, and not less than two (2) years of experience;
- A baccalaureate degree plus an additional thirty (30) semester hours of college education conferred by an accredited college or university, with the total educational program including an accounting concentration or equivalent, and not less than one (1) year of experience; or
- A post-baccalaureate degree conferred by an accredited college or university, with the total educational program including an accounting concentration or equivalent, and not less than one (1) year of experience.
- An individual, whose principal place of business, domicile, or residency is not in Missouri and who holds a valid and unrestricted license in good standing to practice public accountancy from any state as of December 31, 2024, and who, as of such date, has practice privileges in Missouri, shall continue to have all the privileges of licensees in Missouri without the need to obtain a license or otherwise notify or register with the Missouri State Board of Accountancy or pay any fee.
- An individual with practice privileges may provide compilation, review, or other attest services provided the licensee is associated with a firm holding a current permit to practice in Missouri or any other state.
- The Missouri State Board of Accountancy may by rule require individuals with a valid but restricted license to obtain a license.
- An individual who qualifies for practice privileges may offer or render professional services in Missouri, whether in person, by mail, telephone, or electronic means, and no notice or other submission shall be required of any such individual.
Note: Incidental Practice Exception (See RSMo § 326.283.1(5)) - An out-of-state CPA may temporarily practice in Missouri for professional business incidental to the CPA's regular practice outside Missouri. "Temporary practice" means that practice related to the direct purpose of an engagement for a client located outside of Missouri, which engagement began outside of Missouri and extends into Missouri through common ownership, existence of a subsidiary, assets or other operations located within Missouri.
Firm Practice Privilege/Firm Registration Requirement (See RSMo § 326.289) - All firms practicing public accounting in Missouri must register with the Missouri Secretary of State. Firms which may be exempt from this requirement include:
- Sole proprietorships;
- Trusts created pursuant to revocable trust agreements, of which the trustee is a natural person who holds a license or privilege to practice;
- General partnerships not operating as a limited liability partnership; or
- Foreign professional corporations which do not meet criteria of RSMo § 356 due to name or ownership shall obtain a certificate of authority as a general corporation, which the secretary of state may issue if the corporation meets the requirements of RSMo § 326.289 as described below, and the rules of the Missouri State Board of Accountancy.
- A firm that does not have an office in Missouri may offer or perform attest or compilation services in Missouri without a Missouri firm permit only if it meets each of the following requirements:
- It complies with the following qualifications described in RSMo § 326.289.4(1):
- A simple majority of the ownership of the firm, in terms of financial interests and voting rights of all partners, officers, principals, shareholders, members, or managers, belongs to licensees who are licensed in some state, and the partners, officers, principals, shareholders, members, or managers, whose principal place of business is in Missouri and who perform professional services in Missouri are licensees of Missouri. Although firms may include non-licensee owners, the firm and its ownership shall comply with rules promulgated by the Missouri State Board of Accountancy;
- It complies with the requirements of peer review as set forth in Missouri statutes and rules below;
- It performs such services through an individual with practice privileges; and
- It can lawfully do so in the state where said individual with the privilege to practice has their principal place of business.
- A firm that does not have an office in Missouri may perform other non-attest or non-compilation services while using the title "CPA" or "CPA firm" in Missouri without a Missouri firm permit only if it:
- Performs such services through an individual with practice privileges; and
- Can lawfully do so in the state where said individual with practice privileges has their principal place of business.
Consent to Jurisdiction (See RSMo § 326.283.1(3)) - An individual licensee of another state exercising practice privileges and the firm which employs such licensee hereby simultaneously consent, as a condition of the grant of this privilege:
- To the personal and subject matter jurisdiction and disciplinary authority of the Missouri State Board of Accountancy;
- To comply with the laws and rules of the Missouri State Board of Accountancy;
- That in the event the license from any state is no longer valid or unrestricted, the individual shall cease offering or rendering professional services in Missouri individually and on behalf of a firm; and
- To the appointment of the state board that issued the individual's license as their agent upon whom process may be served in any action or proceeding by the Missouri State Board of Accountancy against the individual.
Peer Review Requirement (See RSMo § 326.289.1(2)(b) and (.9) and 20 CSR 2010-5.080) - Any firm that does not have an office in Missouri may offer or perform attest or compilation services in Missouri without a valid permit only if it meets Missouri peer review requirements in addition to the requirements of RSMo § 326.289.1(2) described above.
- Any firm which has performed one (1) or more attest engagements, reviews, or compilations, in any calendar year, shall enroll in an approved peer review program.
- Firms must enroll in an approved peer review program within ninety (90) days after entering into an engagement for its first attest, review, or compilation service.
- The firm’s initial peer review shall be completed within eighteen (18) months of enrollment.
- Peer reviews shall occur at least once every three (3) years.
- The firm shall verify that any member of the firm who is responsible for supervising attest or review services, or signs or authorizes someone to sign, the firm's report on attest or review engagements on behalf of the firm, has met the competency requirements as prescribed in 20 CSR 2010-2.061.
- For firms that are enrolled in an approved peer review program in another state, the firm shall verify that the office follows the same quality control policies and procedures established by the firm that has been subjected to the peer review process in the other state.
Additional Requirements (See RSMo § 326.283.1(4)) - An individual who has been granted practice privileges who performs attest or compilation services shall comply with the provisions of RSMo § 326.289 as listed above.
Restrictions (See RSMo § 326.292.1 and .9 and 20 CSR 2010-2.022(6)) - Only licensees may issue a report on financial statements of any person, firm, organization or governmental unit or offer to render or render any attest service. Such restriction shall not prohibit any act of a public official or public employee in the performance of the person's duties as such; nor prohibit the performance by any non-licensee of other services involving the use of accounting skills, including the preparation of tax returns, management advisory services and the preparation of nonattest financial statements. Non-licensees may prepare financial statements and issue nonattest transmittals or information thereon which do not purport to be in compliance with the Statements on Standards for Accounting and Review Services (SSARS).
- No licensee shall perform attest or compilation services through any CPA firm that does not hold a valid permit issued under RSMo § 326.289.
- The lack of a Missouri license, practice privilege or otherwise, shall not prevent the Missouri State Board of Accountancy from having disciplinary authority over any individual practicing public accounting in Missouri.
Definitions (See RSMo § 326.256) - "Attest" or "attest services" means providing the following services:
- Any audit or other engagement to be performed in accordance with the Statements on Auditing Standards (SAS);
- Any examination of prospective financial information to be performed in accordance with the Statements on Standards for Attestation Engagements (SSAE);
- Any engagement to be performed in accordance with the auditing standards and rules of the Public Company Accounting Oversight Board (PCAOB);
- Any review of a financial statement to be performed in accordance with SSARS; or
- Any examination, review, or agreed upon procedures engagement to be performed in accordance with the SSAE, other than an examination described above.
- "Certified public accounting firm", "CPA firm" or "firm", means a sole proprietorship, a corporation, a partnership, or any other form of organization issued a permit or otherwise authorized to practice under RSMo § 326.289.
- "Compilation" means providing a service to be performed in accordance with SSARS that is presented in the form of financial statements information that is the representation of management (owners) without undertaking to express any assurance on the statements.
- "Peer review" means a study, appraisal or review of one (1) or more aspects of the professional work of a CPA firm that performs attest or compilation services, by licensees who are not affiliated either personally or through their CPA firm being reviewed pursuant to the Standards for Performing and Reporting on Peer Reviews promulgated by the AICPA or such other standard adopted by regulation of the Missouri State Board of Accountancy which meets or exceeds the AICPA standards.
- "Principal place of business" means the office location designated by the licensee for purposes of mobility and reciprocity.
- "Report", when used with reference to any 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 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. The term report includes any form of language which disclaims an opinion when such 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 such language, and includes any other form of language that is conventionally understood to imply such assurance or such special knowledge or competence.
- "State" means any state of the United States, the District of Columbia, Puerto Rico, the U.S. Virgin Islands, the Commonwealth of the Northern Mariana Islands, and Guam; except that "this state" means the state of Missouri.
Statute and/or Regulation References RSMo § 326.256; § 326.283; § 326.289; and § 326.292; 20 CSR 2010-2.022 and 2010-5.080
Two (2)-Tiered States - For mobility purposes, "CPA license" means a CPA license granted by the state board after all education, exam, and experience requirements have been met. A CPA performing services through mobility may only perform the same level of services (attest or non-attest) in the mobility jurisdiction as they are permitted to perform in the home jurisdiction. Please note the following if you are coming from one (1) of the jurisdictions listed:
- An Alabama certificate holder, holding other than an active license with a permit to practice, may not hold out or practice as a CPA in a mobility jurisdiction.
- A Connecticut certificate holder may not hold out or practice as a CPA in a mobility jurisdiction.
- An Illinois certificate or registered certificate holder may not hold out or practice as a CPA in a mobility jurisdiction.
- Both a Hawaii CPA license and permit are required in order to hold out or practice as a CPA in a mobility jurisdiction.
- A Kansas certificate holder may not hold out or practice as a CPA in a mobility jurisdiction.
- Both a Montana CPA certificate and permit are required in order to hold out or practice as a CPA in a mobility jurisdiction.
- Both a Nebraska CPA certificate and permit are required in order to hold out or practice as a CPA in a mobility jurisdiction.
- An Oklahoma registrant must hold an active permit In order to hold out or practice as a CPA in a mobility jurisdiction.
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.
Last reviewed October 22, 2026 |
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