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, New Jersey, Texas, and Pennsylvania have adopted the UAA Safe Harbor Language for Mobility.
Effective August 6, 2008:
Individual Practice Privilege - An individual whose principal place of business is not in Colorado shall be presumed to have qualifications substantially equivalent to Colorado's requirements and shall have all the privileges of licensees of Colorado without the need to obtain a Colorado CPA license if the individual:
- Holds an active certificate or license issued by any state that the National Association of State Boards of Accountancy's (NASBA) national qualification appraisal service has verified to be substantially equivalent to the CPA licensure requirements of the AICPA/NASBA Uniform Accountancy Act (UAA); OR
- The individual holds an active certificate or license issued by any state that NASBA’s national qualification appraisal service has not verified to be substantially equivalent with the CPA licensure requirements of the UAA, but such individual obtains from NASBA’s national qualification appraisal service verification (CredentialNet) that such individual’s CPA qualifications are substantially equivalent to the CPA licensure requirements of the UAA.
NOTE: Any individual who passed the Uniform CPA Exam and holds a valid license issued by any other state prior to January 1, 2012, shall be exempt from the UAA's education requirement. - Practice privileges extend to the offering or rendering of professional services, whether in person, or by mail, telephone, or electronic means, and no notice or other submission shall be provided by any individual exercising the privilege.
Foreign Individuals: An individual who holds a degree, certificate, or license in a foreign country to practice public accounting may provide professional services in this state without a certificate issued under the Act or a certificate or license issued by another U.S. jurisdiction, provided that: - The degree, certificate, or license is a recognized qualification for the practice of public accounting in that country and the certificate or license is active and in good standing;
- The individual’s principal place of business, as defined in 3 Code Colo. Regs. § 705-1(1.14)(B), is not in this state; and
- The practice is incident to the individual’s regular practice outside this state. “Incident to” means the professional services provided are temporary and a subordinate component of professional services otherwise performed outside of this state.
Contact Information Required (See 3 Code Colo. Regs. § 705-1(1.14)(B)(3)) Any person authorized to use the title "Certified Public Accountant" or "CPA" must provide an address and telephone number for the CPA's firm or sole practitioner to any client residing in or headquartered in Colorado.
Firm Practice Privilege/Firm Registration Requirement
Consent to Jurisdiction (See 3 Code Colo. Regs. § 705-1(1.14)(C)) - Licensees who hold a practice privilege are subject to jurisdiction and the disciplinary authority of the Colorado Board of Accountancy. The Colorado Board of Accountancy may deny, revoke, suspend, fine, issue a letter of admonition, place on probation, impose other conditions or limitations or deny the practice privilege to the holder for violation of the Colorado State Board of Accountancy's laws or rules.
- If an individual practice privilege holder's certificate, license or permit to practice as a CPA or the firm's permit is limited or subjected to any form of discipline or denial by a jurisdiction other than Colorado while exercising the practice privilege in Colorado, the practice privilege holder must notify the Colorado State Board within thirty (30) days of the action taken by the other jurisdiction.
Peer Review Requirement N/A
Additional Requirements N/A
Restrictions N/A
Definitions - "Financial statements": Statements and related disclosures that purport to show an actual or anticipated financial
position that relates to a point in time, or results of operations, cash flow, or changes in financial position that relate to a period of time, on the basis of U.S. GAAP or another comprehensive basis of accounting. The term includes specific elements, accounts, or items of such statements, but does not include incidental financial data included in
management advisory services reports to support recommendations to a client, nor does it include tax returns and supporting schedules. - “Principal Place of Business” is presumed to be the location designated by the individual, but the presumption will be overcome if:
- the individual establishes residency in Colorado; and
- the individual provides or offers professional services to his employer or to a client or potential client located in Colorado. Provided further that if the individual submits an application for a Colorado certificate within sixty (60) days of establishing residency in Colorado, the individual may continue to have all the privileges of a certificate holder until
such time as a Colorado certificate is granted or denied.
- "Substantial Equivalency": A determination by the Colorado State Board of Accountancy or its designee that the education, examination, and experience requirements contained in the statutes and administrative rules of another jurisdiction are comparable to or exceed the education, examination, and experience requirements contained in the AICPA/NASBA Uniform Accountancy Act (UAA) or that an individual CPA’s education, examination, and experience qualifications are comparable to or exceed the requirements contained in the UAA.
Statute and/or Regulation Reference CO Rev Stat § 12-100-117
3 Code Colo. Regs. § 705-1(1.14)(B)(2)
3 Code Colo. Regs. § 705-1(1.14)(C)
3 Code Colo. Regs. § 705-1(1.14)(D)
Two (2)-Tiered States For mobility purposes, "CPA license" means a CPA license or certificate granted by Board of Accountancy 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 he or she is 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 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. |
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