The US CPE Annual Floor Runs From Zero to Forty Hours

Illinois lets a CPA complete no continuing education at all for two years and then 120 hours in the third. Michigan makes 39 hours in a year a breach regardless of what the licensee did the year before, and then charges four penalty hours for every month of deficiency that do not count toward the requirement. Both states are routinely described as requiring "about 40 hours a year". They are not remotely the same obligation.

The real spread is in the annual floor, not the total

Totals across large states cluster: 80 hours over two years, or 120 over three, with a couple of annual regimes. The annual floor inside those totals runs from nothing to the entire requirement.

No annual floor at all. Illinois requires 120 hours every three-year renewal period and states no annual minimum anywhere in the rule. It is the only state we examined with a multi-year total and no floor whatsoever, and the Department's own guidance confirms the absence. Total back-loading is lawful.

Floors of 20 inside a larger total. Ohio requires a minimum of twenty credits annually inside 120 per triennium. Pennsylvania requires at least 20 hours in each calendar year inside 80 per biennium. Georgia's official code requires a minimum of 20 of the 80 hours to be earned in each year.

California's floor has a floor inside it. Twenty hours in each year of the two-year period, and within that, a minimum of 12 hours of the required 20 in technical subject areas. No other state we examined imposes an annual subject-matter floor as well as an annual volume floor.

The annual figure is the whole requirement. Michigan requires at least 40 hours for each year of a licence cycle, by statute rather than by rule. North Carolina requires 2,000 CPE minutes by 31 December each year, which is forty credit-equivalents though the rule says neither forty nor hours. New York requires either 40 contact hours a year, or 24 if concentrated in one recognised area of study — and there is no three-year total at all, which we return to below.

Not found. Florida's statute and the Department's own page state no annual minimum within the two-year reestablishment period.

And one we will not report. A 20-hour annual minimum is widely asserted for Texas. We could not verify it from any primary source and we are not asserting it. The reason is worth stating plainly: the Texas Administrative Code has migrated to a reader that serves no rule text to automated retrieval at all, and the board's own renewal and CPE-entry guidance states no annual floor. Every Texas figure in circulation is therefore board-guidance-sourced rather than rule-verified, including ours.

Why Michigan is the outlier worth understanding

Michigan's requirement sits in statute, not in board rules, and the legislature did three unusual things with it.

It made 40 hours a hard annual requirement rather than a floor inside a biennial total, with excess hours carrying over to the next year only, never to a later one, and capped at 40.

It made accounting and auditing unconditional: at least 8 of the 40 hours each year, for every licensee, whether or not they perform attest work. California, Pennsylvania and Ohio each require 24 hours of accounting and auditing only if the licensee does attest or similar work. Michigan's 8 hours a year, 16 per biennium, is the only unconditional annual mandate of its kind among the states we examined.

And it capped its own regulator. The statute provides that the board shall not require completion of more than 8 hours in that area in one year. A legislature limiting a professional board's power to demand more technical CPE is not a common feature of these regimes.

New York is a different shape entirely

New York is the state most often mis-described, and the error is structural rather than numerical.

Its obligation is per calendar year, and the annual figure is the requirement: 40 contact hours of formal continuing education, or 24 if concentrated in one recognised area. Tracking runs 1 January to 31 December. Registration, however, is triennial, and a licensee affirms compliance for each calendar year in the registration period rather than reporting annually.

So a New York CPA taking the concentrated option lawfully completes 72 hours in a triennium; one taking the general option completes 120. Any table listing New York as "120 per three years" is wrong, and any table listing it as "40 per year" without the 24-hour concentration option is also wrong.

Six different clocks

The periods are as varied as the floors, and they cannot be aligned.

Pennsylvania runs a fixed calendar biennium, 1 January of the even year to 31 December of the odd year, identical for every licensee. Ohio runs a fixed calendar triennium. Illinois runs a fixed triennium expiring 30 September. California runs a licence-anniversary biennium to the last day of the licensee's birth month, split into two annual windows on the same anchor. Texas renews annually against a rolling three-year CPE period, on the birth month. New York and North Carolina both measure CPE on the calendar year but renew on other cycles — triennially for New York, before 1 July for North Carolina. Michigan's continuing education period runs 1 July to 30 June, the only mid-year period among them.

The practical consequence is that a dual licensee generally cannot build one annual plan. A California and Michigan licensee is tracking a birth-month year with a 12-hour technical sub-floor against a July-to-June year with a hard 40 hours including 8 accounting and auditing and 2 ethics. And any dual licensee whose second state has an annual floor is governed by that floor in practice, which makes Illinois's flexibility worthless to them.

Shortfall is where the designs diverge most

Four quite different philosophies, and none of them is "lose your licence".

Michigan charges penalty hours at a monthly rate, and they do not count: a deficient licensee reports 80 qualifying hours plus an additional four hours for each month of time needed to remove the deficiency, with those extra hours excluded from the qualifying total. Florida's penalty is subject-specific rather than volume-based: an extension to mid-September requires an additional 8 hours in accounting and auditing, and to the end of December an additional 16 — and its statute caps the board's power to impose penalty hours at 25% of the total required. Ohio charges money, at one hundred dollars for each full month or part of a month, and places a licensee disciplined for CPE non-compliance under ongoing verification for at least two triennial reporting periods. North Carolina runs the only express two-strikes rule we found: a letter of warning for the first failure in a five-year period, and on a second failure the Board may deny renewal for not less than 30 days.

Illinois and Pennsylvania specify no penalty hours or fines in the materials we could read; Illinois instead provides a hardship waiver, under which a timely applicant is deemed to be in good standing until the Division decides.

What to take from this

A headline hours figure, on its own, tells you almost nothing about what a US CPA must actually do. The floor determines whether the requirement can be planned around at all; the clock determines whether two licences can share a plan; and the shortfall regime determines what being late actually costs. Those three travel with the number or the number is misleading.

The same lesson applies wherever a profession is regulated locally rather than nationally, which is why we keep returning to it: see our analysis of how US nurse CE record retention varies by state for the same pattern in healthcare. For why there is no single American rule to begin with, see who actually sets CPE for a US CPA, and for the ethics dimension, which is where dual licensees lose the most time, see the four different ethics regimes. Michigan's statute is published by the Michigan Legislature, and every figure above should be confirmed at the board or statute before being relied on.