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, Delaware, Texas, and Pennsylvania 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 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 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.
- Notwithstanding any provision of law to the contrary, if the Virginia Board of Accountancy determines after evaluation that another state has granted CPA license without requiring candidates to meet minimum qualifications acceptable to the Virginia Board of Accountancy, the Virginia Board of Accountancy may revoke practice privileges in Virginia for CPAs licensed by that state. Individual CPAs from states for which practices privileges have been revoked can still qualify for practice privileges in Virginia if the person would qualify for licensure in Virginia.
Firm Practice Privilege/Firm Registration Requirement Licensing requirement for firms - Only a licensed firm can provide attest services, compilation services, or financial statement preparation services to persons or entities located in Virginia. However, this shall not affect the privilege of a person who is not licensed to include a statement on financial statements indicating that no assurance is provided on the financial statements, to say that financial statements have been compiled, or to use the compilation language, as prescribed by Code of Virginia § 54.1-4401(B) and (C).
- A firm that provides attest services, compilation services, or financial statement preparation services to persons or entities located in Virginia shall obtain a Virginia license if such firm's principal place of business is in Virginia.
Firm Practice Privileges - 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; 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.
Virginia Firm Ownership Requirement - For a firm to obtain and hold a Virginia license:
- As determined on a firm-wide basis:
- 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 Board 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 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 Virginia Board of Accountancy.
- If the services provided by the firm are within the scope of the practice-monitoring program of the American Institute of Certified Public Accountants or its successor, the firm shall enroll in the program or in another practice-monitoring program for attest services, compilation services, and financial statement preparation services that is approved by the Virginia Board of Accountancy. In addition, if enrolled the firm shall:
- Comply with any requirements prescribed by the Virginia Board of Accountancy in response to the results of peer reviews; and
- Participate in the American Institute of Certified Public Accountants' (AICPA), or sponsoring organizations', Facilitated State Board Access process, or its successor process, or another process approved by the Virginia Board of Accountancy for peer reviews.
- The name of the firm shall not be false, misleading, or deceptive.
The Virginia Board of Accountancy shall prescribe the methods and fees for a firm to apply for the issuance, renewal, or reinstatement of a Virginia license.
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 the practice privileges section above.
Consent to Jurisdiction To use the CPA title in Virginia, the person shall: - Consent to be subject to:
- The provisions of this chapter and regulations promulgated by the Virginia Board of Accountancy that apply to the holder of a Virginia license;
- The jurisdiction of the Virginia Board of Accountancy 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 Board'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 Virginia Board of Accountancy.
- 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 Virginia Board of Accountancy 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 Virginia Board of Accountancy 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 Virginia Board of Accountancy for an act or omission committed in that state. The Virginia Board of Accountancy 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 Virginia Board of Accountancy 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 Virginia Board of Accountancy and comparable statutes or regulations of other states or boards of accountancy.
Peer Review Requirement - If the services provided by the firm are within the scope of the practice-monitoring program of the American Institute of Certified Public Accountants or its successor, the firm shall enroll in the program or in another practice-monitoring program for attest services, compilation services, and financial statement preparation services that is approved by the Virginia Board of Accountancy. In addition, if enrolled the firm shall:
- Comply with any requirements prescribed by the Virginia Board of Accountancy in response to the results of peer reviews; and
- Participate in the American Institute of Certified Public Accountants', or sponsoring organizations', Facilitated State Board Access process, or its successor process, or another process approved by the Virginia Board of Accountancy for peer reviews.
Additional Requirements N/A
Restrictions Notwithstanding any provision of law to the contrary, if the Virginia Board of Accountancy determines after evaluation that another state has granted CPA license without requiring candidates to meet minimum qualifications acceptable to the Virginia Board of Accountancy, the Virginia Board of Accountancy may revoke practice privileges in Virginia for CPAs licensed by that state. Individual CPAs from states for which practices privileges have been revoked can still qualify for practice privileges in Virginia if the person would qualify for licensure in Virginia.
Relevant Definitions - “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, by the Auditing Standards Board or the Accounting and Review Services Committee of the American Institute of Certified Public Accountants, 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 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.
- "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.
- "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 portraying 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 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 § 54.1-4411
Code of Virginia § 54.1-4412.1
Code of Virginia § 54.1-4413.3
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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