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 September 1, 2025:
Individual Practice Privilege (See Tex. Occ. Code § 901.462 and 22 Tex. Admin. Code § 517.2) - An individual who holds an active certificate or license as a CPA 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 Texas certificate or license if the individual:
- Has passed the Uniform CPA Examination;
- Has completed:
- A baccalaureate degree with at least one hundred 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 above 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 Texas State Board of Public Accountancy (TSBPA).
- Notwithstanding any other law, the TSBPA may prohibit an individual not licensed in Texas from exercising the privileges of certificate and license holders of Texas if the TSBPA determines the individual does not meet the requirements above.
- An individual who on December 31, 2024, held a certificate or license issued by another state and practiced under a privilege in Texas may exercise all the privileges of a Texas certificate and license holder, without obtaining a certificate or license in Texas. To the extent that the individual exercises practice privileges, the individual is subject to Texas statutes and rules.
Consent to Jurisdiction for Individual Mobility (See Tex. Occ. Code § 901.462(c)-(d) and 22 Tex. Admin. Code § 517.3) - An individual practicing under the privilege offered in Texas, 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 TSBPA 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.
- An individual practicing under a privilege offered in Texas 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.
Firm Practice Privilege/Firm Registration Requirement (See Tex. Occ. Code § 901.354; § 901.461; and 22 Tex. Admin. Code § 517.1) - A CPA firm that is not licensed in Texas but is licensed in another state may practice in Texas without a firm license or notice to the TSBPA if the firm’s practice in Texas is performed by an individual who holds a Texas license or who holds practice privileges in Texas.
- A firm described above may exercise all the practice privileges of a Texas firm license holder, except that the firm may perform attest services for an entity with its home office in Texas only if:
- The firm meets the following ownership requirements:
- A majority of the ownership of the firm, in terms of financial interests and voting rights, must belong to CPAs licensed in Texas or another state. A firm and its owners shall comply with TSBPA rules regardless of whether the firm includes owners who are not license holders; and
- A CPA firm may include individuals as owners who are not license holders if:
- The firm designates to the 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 Texas resident is actively involved in the firm or an affiliated entity; lacks a history of dishonest or felonious acts; maintains any professional designation in good standing with the appropriate organization or regulatory body that is identified or used in any firm-related communication; has passed an examination on, and complies with, the rules of professional conduct as determined by the TSBPA; and
- The firm and the owners who are not CPAs comply with TSBPA disciplinary actions and other requirements the TSBPA may impose by rule.
- The firm complies with the TSBPA Peer Review Program; and
- The services are performed by an individual who holds a Texas license or holds practice privileges in Texas.
Consent to Jurisdiction for Firm Mobility (See Tex. Occ. Code § 901.461(c)-(d) and 22 Tex. Admin. Code § 517.3) - A firm practicing under the privilege offered in Texas, 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; and
- 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.
- A firm practicing under a privilege offered in Texas shall promptly cease offering or rendering professional services in Texas if the firm's license to practice as a CPA firm in the state in which the firm's principal place of business is no longer valid.
Peer Review Requirement (See Tex. Occ. Code § 901.159; § 901.461(b)(2); 22 Tex. Admin. Code § 517.3(d); and § 527.1 through .12) - An out-of-state firm practicing in Texas pursuant to a practice privilege must comply with the peer review program of the state in which the firm is licensed.
- An out-of-state firm practicing in Texas pursuant to a practice privilege from a state without a peer review program must comply with Texas peer review requirements.
- A firm that performs an engagement that is required to be performed in accordance with the Statements on Standards for Accounting and Review Services (SSARS), such as compilations and reviews, is performing an attest service and must comply with peer review provisions.
- Participation in the Texas Peer Review Program is required of each firm licensed or registered with the TSBPA that performs any attest services, including:
- audits, reviews, compilations, and any "special reports" that purport to express an opinion that the financial statements or any material portion thereof are in accordance with Generally Accepted Accounting Principles (GAAP) and the CPA firm did its engagement in accordance with the Statement on Auditing Standards (SAS) or SSARS as it applies to Reviews and Compilations (only).
- A firm that performs attest services subject only to Public Company Accountancy Oversight Board (PCAOB) inspection is NOT required to participate in the peer review program.
- A firm whose highest level of service is preparation engagements under SSARS is NOT required to participate in the peer review program.
- The TSBPA shall provide for a peer review program to review the work product of a license holder or of the CPA 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 CPA 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 TSBPA adopts Standards for Performing and Reporting on Peer Reviews promulgated by the American Institute of CPAs (AICPA).
- Qualified sponsoring organizations shall be the AICPA, the TXCPA, and state CPA societies fully involved in the administration of the AICPA Peer Review Program, and such other entities which are approved by the TSBPA.
- Each firm required to participate shall enroll in the applicable peer review program of an approved sponsoring organization within thirty (30) days of performing services that require a review. The firm shall adopt the review due date assigned by the sponsoring organization, and must notify the TSBPA of the peer review due date within thirty (30) days of its assignment. In addition, a firm's subsequent peer review is due three (3) years and six (6) months after the year end of the previous peer review, or earlier as may be required by the sponsoring organization, a committee of the TSBPA, or the TSBPA executive director. It is the responsibility of the firm to anticipate its needs for peer review services in sufficient time to enable the reviewer to complete the peer review by the assigned review due date.
- In the event that a firm is merged, otherwise combined, dissolved, or separated, the sponsoring organization shall determine which firm is considered the successor firm. The successor firm shall retain its peer review status and the review due date.
Additional Requirements (See 22 Tex. Admin. Code § 517.3(c)) - A firm that practices in Texas under a practice privilege must use the firm name that it uses in the state in which it is licensed and has its principal place of business.
Restrictions (See Tex. Occ. Code § 901.456 and § 901.460) - A certificate holder may perform attest services only in a CPA firm.
- An individual who is a license holder or practices under a privilege in Texas and who is responsible for supervising attest services or signs or authorizes another person to sign an accountant's reports on financial statements on behalf of a CPA firm must meet the competency requirements of professional standards that apply to those services.
- Only a license holder or a person who practices under a privilege in Texas may issue a report on a financial statement of another person or otherwise perform or offer to perform an attest service.
- A person who is not a license holder and who does not practice under a privilege in Texas:
- May not use language in any statement related to the financial affairs of a person that is conventionally used by license holders in reports on financial statements;
- May prepare financial statements; and
- May issue nonattest transmittals or information regarding nonattest transmittals if the transmittals or information do not purport to be in compliance with SSARS adopted by the AICPA or another national accountancy organization recognized by the TSBPA.
- A license holder or individual who practices under a privilege in Texas who performs attest services must provide those services in accordance with standards adopted by the AICPA or another national accountancy organization recognized by the TSBPA.
Definitions 22 Tex. Admin. Code § 501.52
- “Attest service” means:
- An audit or other engagement required by the TSBPA to be performed in accordance with SAS adopted by the AICPA, PCAOB, or another national or international accountancy organization recognized by the TSBPA;
- A review or compilation required by the TSBPA to be performed in accordance with SSARS adopted by the AICPA or another recognized national or international accountancy organization;
- An engagement required by the TSBPA to be performed in accordance with Statements on Standards for Attestation Engagements (SSAE) adopted by the AICPA or another recognized national or international accountancy organization; or
- Any other assurance service required by the TSBPA to be performed in accordance with professional standards adopted by the AICPA or another recognized national or international accountancy organization.
- “Firm” means a sole proprietorship, partnership, limited liability partnership, limited liability company, corporation, or other legally recognized business entity engaged in the practice of public accountancy.
- “Peer Review,” "Quality Review," or "Compliance Assurance" 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.
Tex. Occ. Code § 901.003
- “Practice of Public Accountancy” means:
- The performance for a client by a person who is certified, licensed, or registered in Texas 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 in Texas of a service that involves the use of accounting, attesting, or auditing skills;
- The performance of activities of a person or practice unit licensed in Texas 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 above.
- 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.
- A person represents to the public that the person is certified, licensed, or registered in Texas 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.
Tex. Occ. Code § 901.002
- “Professional accounting services” or “professional accounting work” means services or work that requires the specialized knowledge or skills associated with CPAs, including:
- issuing reports on financial statements;
- providing management or financial advisory or consulting services;
- preparing tax returns; and
- providing advice in tax matters.
Tex. Occ. Code § 901.0021
- “Report” means:
- 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 SSARS adopted by the AICPA 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 Texas Occupational Code § 901.002-.003; § 901.159; § 901.461; and § 901.462
22 Texas Administrative Code § 501.52; § 517.1-.3; and § 527
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 August 28, 2026 |
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