Practice Privileges.
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 September 1, 2025:
Individual Practice Privilege - An individual who holds an active certificate or license as a certified public accountant issued by another state and whose principal place of business is not in Texas may exercise all the privileges of certificate and license holders of Texas without obtaining a certificate or license under the Texas Accountancy Act § 901.462 if the individual:
- has passed the uniform CPA examination;
- has completed:
- a baccalaureate degree with at least one hundred and fifty (150) semester hours and a concentration in accounting or equivalent courses;
- a graduate degree with a concentration in accounting or equivalent courses; or
- a baccalaureate degree with a concentration in accounting or equivalent courses; and
- at the time the individual's certificate or license was issued in the other state, had completed:
- at least one (1) year of work experience, if licensed under an educational pathway comparable to a baccalaureate degree with at least one hundred and fifty (150) semester hours and a concentration in accounting or equivalent courses or to a graduate degree with a concentration in accounting or equivalent courses; or
- at least two (2) years of work experience, if licensed under an educational pathway comparable to a baccalaureate degree with a concentration in accounting or equivalent courses.
- An individual who meets the requirements listed under bullet one (1) and who offers or renders professional services in person or by mail, telephone, or electronic means may practice public accountancy in Texas without notice to the TSBPA.
- Notwithstanding any other law, the Texas State Board of Public Accountancy (TSBPA) may prohibit an individual not licensed in Texas from exercising the privileges of certificate and license holders of Texas if TSBPA determines the individual does not meet the requirements of one (1) of the above mentioned pathways.
- An individual who on December 31, 2024, held a certificate or license issued by another state and practiced under a privilege of this section in Texas may exercise all the privileges of the holder of a certificate and license issued under the Texas Accountancy Act § 901.462, without obtaining a certificate or license in Texas. To the extent that the individual exercises privileges as described by this subsection, the individual is subject to the Texas Accountancy Act § 901.462.
Firm Practice Privilege/Firm Registration Requirement See the Texas Accountancy Act § 901.461 and also Texas Administrative Code (Rule) § 517.1.
Firm Ownership Requirement - An applicant for initial issuance or renewal of a firm license must show that a majority of the ownership of the firm, in terms of financial interests and voting rights, belongs to persons who hold certificates issued under the Texas Accountancy Act § 901.354 or are licensed in another state. A firm and its owners shall comply with TSBPA rules regardless of whether the firm includes owners who are not license holders.
- A certified public accountancy firm may include individuals as owners who are not license holders if:
- the firm designates to TSBPA as responsible for the firm’s license a license holder who resides in Texas;
- each owner who is not a license holder and who is a resident of Texas as determined by TSBPA rule:
- is actively involved in the firm or an affiliated entity;
- lacks a history of dishonest or felonious acts;
- maintains any professional designation held by the individual in good standing with the appropriate organization or regulatory body that is identified or used in an advertisement, letterhead, business card, or other firm-related communication;
- has passed an examination on the rules of professional conduct as determined by TSBPA rule; and
- complies with the rules of professional conduct as determined by TSBPA rule; and
- the firm and the owners who are not license holders comply with TSBPA disciplinary actions and other requirements the TSPBA may impose by rule.
See the Texas Accountancy Act § 901.354.
Consent to Jurisdiction for Individual Mobility - An individual practicing under the privilege under the Texas Accountancy Act § 901.462, as a condition of the privilege of practicing without a certificate or license:
- is subject to the personal and subject matter jurisdiction and disciplinary authority of the TSBPA;
- must comply with the Texas Accountancy Act and the Texas State Board of Public Accountancy’s rules; and
- is considered to have appointed the regulatory agency of the state that issued the individual’s certificate or license as the agent on whom process may be served in any action or proceeding by the TSBPA against the individual.
See the Texas Accountancy Act § 901.462(c) and also Texas Administrative Code (Rule) § 517.3.
Consent to Jurisdiction for Firm Mobility - A firm practicing under a privilege under the Texas Accountancy Act § 901.461, as a condition of the privilege of practicing without a firm license:
- is subject to the personal and subject matter jurisdiction and disciplinary authority of the TSBPA;
- must comply with the Texas Accountancy Act and TSBPA rules; an
- is considered to have appointed the regulatory agency of the state that issued the firm’s license as the firm’s agent on whom process may be served in any action or proceeding by the TSBPA against the firm.
See the Texas Accountancy Act § 901.461(c) and also Texas Administrative Code (Rule) § 517.3.
Firm Mobility Peer Review Requirement - TSBPA by rule shall provide for a peer review program to review the work product of a license holder or of the certified public accountancy firm in which the license holder is a member, in lieu of the license holder, to the extent necessary to comply with any applicable standards adopted by generally recognized bodies responsible for setting accounting standards.
- Peer review must include a verification that each individual in a certified public accountancy firm who is responsible for supervising attest services and who signs or authorizes another person to sign an accountant’s reports on financial statements on behalf of the firm meets the competency requirements of the professional standards that apply to those services.
- The TSPBA by rule shall establish a fee in an amount not to exceed $200 to be paid by a certified public accountancy firm, or by a license holder who is not a member of a certified public accountancy firm, for each peer review required by the TSBPA under this section.
See the Texas Accountancy Act § 901.159 and Texas Administrative Code (Rule) § 517.3.
Additional Requirements N/A
Restrictions - An individual who practices under a privilege under the Texas Accountancy Act § 901.462(d) shall promptly cease offering or rendering professional services in Texas if the individual’s certificate or license in the state of the individual’s principal place of business is no longer valid.
See the Texas Accountancy Act § 901.462(d) - A firm practicing under a privilege under the Texas Accountancy Act § 901.462(d) shall promptly cease offering or rendering professional services in Texas if the firm’s license to practice as a certified public accountancy firm in the state in which the firm’s primary place of business is no longer valid.
See the Texas Accountancy Act § 901.461(d) and also Texas Administrative Code (Rule) § 517.3.
Relevant Definitions - “Attest service” in Texas means:
- an audit or other engagement required by TSBPA to be performed in accordance with the auditing standards adopted by the American Institute of Certified Public Accountants or another national accountancy organization recognized by TSBPA;
- an engagement required by the TSBPA to be performed in accordance with standards for accounting and review services adopted by the American Institute of Certified Public Accountants or another national accountancy organization recognized by the TSBPA;
- an engagement required by the TSBPA to be performed in accordance with standards for attestation engagements adopted by the American Institute of Certified Public Accountants or another national accountancy organization recognized by the TSBPA; or
- any other assurance service required by TSBPA to be performed in accordance with professional standards adopted by the American Institute of Certified Public Accountants or another national accountancy organization recognized by TSBPA.
- “Firm” in Texas means a sole proprietorship, partnership, corporation, limited liability company, or other business entity engaged in the practice of public accountancy.
- “Peer review” in Texas means the study, appraisal, or review of the professional accounting work of a public accountancy firm that performs attest services by a certificate holder who is not affiliated with the firm.
- “Practice of Public Accountancy” in Texas means:
- In the Texas Accountancy Act, “practice of public accountancy” means:
- the performance for a client by a person who is certified, licensed, or registered under the Texas Accountancy Act of a service that involves the use of accounting, attesting, or auditing skills;
- the performance or offer of performance for a client or potential client by a person who represents to the public that the person is certified, licensed, or registered under this the Texas Accountancy Act of a service that involves the use of accounting, attesting, or auditing skills;
- the performance of activities of a person or practice unit licensed under this the Texas Accountancy Act in:
- preparing or reporting on a financial statement or report that is to be used by an investor, the management of an organization, a third party, or a financial institution, unless the report is prepared for internal use only; or
- preparing a tax return that is filed with a taxing authority; or
- The supervision of an activity described by Subdivision (3).
- For purposes of this section, a service that involves the use of accounting, attesting, or auditing skills includes:
- issuing a report on or preparing a financial statement;
- providing management or financial advisory or consulting services; and
- preparing a tax return or advising or consulting on a tax matter.
- For purposes of this section, a person represents to the public that the person is certified, licensed, or registered under the Texas Accountancy Act if the person makes an oral or written representation that the person is certified, licensed, or registered. A written representation includes a representation communicated by office sign, business card, letterhead, or advertisement. A representation does not include:
- the display of an original certificate or registration unless a license is also displayed;
- a representation made by a faculty member of an educational institution solely in connection with the duties of the person as a faculty member; or
- a representation in a book, article, or other publication, or a representation made in connection with the promotion of the publication, unless the representation includes an offer to perform a service or to sell a product other than the publication.
- “Professional accounting services” or “professional accounting work” in Texas means services or work that requires the specialized knowledge or skills associated with certified public accountants, including:
- issuing reports on financial statements;
- providing management or financial advisory or consulting services;
- preparing tax returns; and
- providing advice in tax matters.
- “Report” in Texas means:
- in the Texas Accountancy Act, a reference to a report used with respect to a financial statement means an opinion, report, or other document, including an assurance prepared in accordance with standards for accounting and review services adopted by the American Institute of Certified Public Accountants or another national accountancy organization recognized by the TSBPA, that:
- states or implies assurance as to the reliability of the financial statement; and
- includes or is accompanied by a statement or implication that the person issuing the opinion, report, or other document has special knowledge or competence in accounting or auditing.
- A statement or implication of assurance as to the reliability of a financial statement or as to the special knowledge or competence of the person issuing the opinion, report, or other document includes any form of language that is conventionally understood to constitute such a statement or implication.
- A statement or implication of special knowledge or competence in accounting or auditing may arise from:
- the use by the issuer of the opinion, report, or other document of a name or title indicating that the person is an accountant or auditor; or
- the language of the opinion, report, or other document itself.
Statute and/or Regulation References The Texas Accountancy Act § 901.159; § 901.354; § 901.461; and § 901.462 of the Occupations Code Texas Administrative Code (Rules) § 517.1 and § 517.3 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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