Mobility is a practice privilege that generally permits a licensed CPA in good standing to practice in a state from outside of his or her 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.
As of July 1, 2025:
Individual Practice Privilege - A person shall be granted practice privilege to provide services to the public in Virginia without notice to the Virginia Board of Accountancy (VBOA) or payment of any fees if the person both:
- Holds a license in good standing issued by another state, territory of the United States, or the District of Columbia; and
- Has passed the Uniform CPA Examination.
- A person who exercises practice privilege in Virginia shall not be required to hold a Virginia license to use the CPA title in Virginia provided that either:
- He provides services to the public and the principal place of business in which he provides those services is in other states, or
- He does not provide services to the public.
Firm Practice Privilege/Firm Registration Requirement - A firm whose principal place of business is not in Virginia is not required to obtain a Virginia license but may provide attest services, compilation services, or financial statement preparation services to persons or entities located in Virginia if the following provisions are met:
- The firm holds the license of another state and can lawfully provide attest services, compilation services, or financial statement preparation services to persons or entities in the state where its principal place of business is located; and
- The firm complies with Virginia firm ownership requirements:
- At least fifty-one (51) percent of the owners of the firm shall be licensees, trustees of an eligible employee stock ownership plan as defined in Code of Virginia § 13.1-543, or a firm that meets this requirement; and
- At least fifty-one (51) percent of the voting equity interest in the firm shall be owned by persons who are licensees, by trustees of an eligible employee stock ownership plan as defined in Code of Virginia § 13.1-543, or by a firm that meets this requirement.
- If the death, retirement, or departure of an owner causes either of these requirements not to be met, the requirement shall be met within one (1) year after the death, retirement, or departure of the owner.
- The VBOA shall prescribe requirements concerning the hours that owners who are not licensees work in the firm and may prescribe other requirements for those persons.
- All attest services, compilation services, and financial statement preparation services provided for persons and entities located in Virginia shall be under the supervision of a person who either:
- holds a Virginia license, or
- holds the license of another state and complies with the practice privileges provisions of Code of Virginia § 54.1-4411.
- Any person who releases or authorizes the release of reports on attest services, compilation services, or financial statement preparation services provided for persons or entities located in Virginia shall:
- Either:
- hold a Virginia license or
- hold the license of another state and comply with the practice privileges provisions of Code of Virginia § 54.1-4411; and
- Meet any additional requirements the Virginia Board of Accountancy (VBOA) prescribes.
- The firm shall conduct its attest services, compilation services, and financial statement preparation services in conformity with the standards of conduct and practice in Code of Virginia § 54.1-4413.3 and regulations promulgated by the VBOA
- The name of the firm shall not be false, misleading, or deceptive.
- A firm may not use the CPA title in Virginia unless it holds a Virginia license or the license of another state as permitted by practice privileges.
Owners of the firm who are not licensees must, based on the facts and circumstances, participate in the firm’s activities on a regular, continuous, and substantial basis.
and - The firm's personnel working on the engagement either:
- hold a Virginia license, or
- hold the license of another state and comply with the practice privilege provisions of Code of Virginia § 54.1-4411; or
- The firm's personnel working on the engagement are under the supervision of a person who either:
- holds a Virginia license or
- holds the license of another state and complies with the practice privilege provisions of Code of Virginia § 54.1-4411.
Consent to Jurisdiction - A person exercising practice privilege who uses the CPA title in Virginia shall:
- Consent to be subject to:
- The provisions of this chapter and regulations promulgated by the Virginia Board of Accountancy (VBOA) that apply to the holder of a Virginia license;
- The jurisdiction of the Virginia Board of Accountancy (VBOA) in all disciplinary proceedings arising out of matters related to his use of the CPA title or providing services to the public in Virginia; and
- The VBOA's authority to revoke or suspend his privilege to use the CPA title in Virginia and to impose penalties for the person's violations of the provisions of this chapter and regulations promulgated by the VBOA.
- Consent to the appointment of the executive director of the board of accountancy of the state that issued the license as his agent, upon whom process may be served
- in any action or proceeding by the VBOA against him, or
- in any civil action in Virginia courts arising out of his using the CPA title in Virginia. In the event he holds a license from more than one (1) state, the VBOA shall establish which executive director shall serve as his agent.
- Consent to the personal and subject matter jurisdiction of the courts of Virginia in any civil action arising out of his use of the CPA title or providing services to the public in Virginia and agree that the proper venue for such actions is in Virginia.
- Agree to cease using the CPA title in Virginia if he is no longer licensed.
- A holder of a Virginia license who is using the CPA title in another state under substantial equivalency or practice privilege provisions of statutes of the state or regulations promulgated by the board of accountancy of the state shall be subject to disciplinary action by the VBOA for an act or omission committed in that state. The VBOA may investigate any complaint made to or by the board of accountancy of any state related to the person's use of the CPA title in that state.
- The VBOA may cooperate and share information with appropriate authorities in other states in investigations or enforcement matters concerning violations of the provisions of this chapter or regulations promulgated by the VBOA and comparable statutes or regulations of other states or boards of accountancy.
Peer Review Requirement
Additional Requirements
Restrictions - Notwithstanding any provision of law to the contrary, if the Virginia Board of Accountancy (VBOA) determines after evaluation that another state has granted CPA license without requiring candidates to meet minimum qualifications acceptable to the VBOA, the VBOA may revoke practice privileges in Virginia for CPAs licensed by that state. Individual CPAs from states for which practice privileges have been revoked can still qualify for practice privileges in Virginia if the person would qualify for licensure in Virginia.
Definitions Code of Virginia § 54.1-4400 (2026 updated section)
- “Attest Services” in Virginia means audit, review, or other engagements performed in accordance with the standards that have been established by the Public Company Accounting Oversight Board (PCAOB), by the Auditing Standards Board or the Accounting and Review Services Committee of the American Institute of Certified Public Accountants (AICPA), or by any successor standard-setting authorities.
- “Compilation Services” in Virginia means compiling financial statements in accordance with standards established by the American Institute of Certified Public Accountants (AICPA) or by any successor standard-setting authorities.
- "Financial statement preparation services" means engaging a licensee in public practice for financial statement preparation services executed in accordance with the standards established by the Statements on Standards for Accounting and Review Services of the American Institute of Certified Public Accountants or by any successor standard-setting authorities.
- “Practice of Public Accounting” in Virginia means the performance of professional services for a client by a licensee or licensee's firm.
- "Professional services" in Virginia means all services requiring substantial use of accountancy or related skills that are performed by a licensee for a client or for an employer. Such services are subject to the guidance of the standard-setting authorities listed in the standards of conduct and practice in Code of Virginia § 54.1-4413.3(5) and 6) or by any equivalent standard-setting authority as approved by the Virginia Board of Accountancy (VBOA).
- "Providing services to or on behalf of an employer" in Virginia means the performance of professional services while employed or engaged on a contractual basis by a licensee to or on behalf of an entity. "Providing services to or on behalf of an employer" does not include a person or firm engaged in the practice of public accounting.
- "Providing services to the public" means providing services that are subject to the guidance of the standard-setting authorities listed in the standards of conduct and practice in Code of Virginia § 54.1-4413.3(5) and 6) or by an equivalent standard-setting authority as approved by the Virginia Board of Accountancy (VBOA).
- "State" means any state of the United States, the District of Columbia, or any territory of the United States that is a recognized jurisdiction by the National Association of State Boards of Accountancy or its successor.
- "Substantially equivalent" means a Board determination that the education requirements of another jurisdiction are comparable to those prescribed by the Board.
- "Using the CPA title in Virginia" means the use of "CPA," "Certified Public Accountant," or "public accountant" in any manner of communication by any person, firm, or entity to persons or entities located in Virginia in a manner that indicates or implies that such person, firm, or entity as being licensed or legally permitted to provide professional services in Virginia. Holding a Virginia license or the license of another state constitutes using the CPA title in Virginia.
- "Virginia license" means a license that is issued by the Virginia Board of Accountancy (VBOA) giving a person or firm the privilege of using the CPA title in Virginia or a firm the privilege of providing attest services, compilation services, and financial statement preparation services to persons and entities located in Virginia.
Statute and/or Regulation References
Code of Virginia § 54.1-4400 (2026 updated section)
Code of Virginia § 54.1-4411
Code of Virginia § 54.1-4412.1
Code of Virginia § 54.1-4413.3
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 7, 2026 |
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