US Ethics CPE Is Not a Yes or No: There Are Four Different Regimes

Every table of US CPE requirements has a column headed something like "state-specific ethics", with a tick or a cross in it. That column is wrong, because the question has four possible answers rather than two, and the four impose genuinely different obligations. A CPA licensed in two states usually cannot satisfy both with one course, and the reason is almost never the one the tables imply.

The four regimes

Across ten large states we found four distinct designs. They are not degrees of strictness on one scale; they constrain different things.

One: the content must be about this state. California requires a two-hour Regulatory Review course, taken from the Board's own approved list, once every six years. Michigan requires that one of its four ethics hours per two-year cycle be a course in Michigan statutes and administrative rules.

Two: the board must have approved the course, but the content need not be local. Florida's statute requires that its ethics requirement be administered by providers approved by the board, and the Department states the consequence in the negative: Florida's rules do not allow a CPA to obtain ethics credit for ethics courses not approved by the Florida Board of Accountancy. Ohio requires three credits in professional standards and responsibilities, with the Board reviewing and approving sponsors, instructors and courses.

Three: the sponsor must hold a registration, and the content is expressly not local. North Carolina requires fifty minutes a year in regulatory or behavioural ethics, offered by a sponsor registered with NASBA. Its Board then says the thing no other board says so plainly: North Carolina-specific ethics courses are not required.

Four: general ethics, no local content and no approval condition found. Illinois requires four hours per three-year period and expressly lists both behavioural ethics and regulatory ethics as eligible fields. Pennsylvania requires four hours in ethics subjects per biennium, with no state-specific or board-approval condition in any of the three Board documents we read.

The precision points that matter in practice

California has two ethics obligations on two different clocks, and one does not satisfy the other. Four hours of general ethics every two years, as part of the 80; and two hours of Regulatory Review every six years, from the Board's list. The Board states in terms that ethics does not satisfy the Regulatory Review requirement. Any source describing California as "four hours, state-specific" has merged two separate requirements into one and will leave a licensee short.

Illinois accepts behavioural ethics; New York's board says it does not. Same nominal four hours, opposite treatment of the same course. A dual licensee who takes a behavioural ethics course satisfies Illinois and not New York.

Ohio's board-approved ethics course may be about another state's law. Its rule permits approved courses to cover Ohio accountancy law and board rules or the accountancy law and rules of another state's board. That is the opposite of what "board-approved ethics" is generally taken to mean, and it makes Ohio a board-approval state rather than a state-specific-content state.

Ohio requires three credits, not four. It is the only one of the ten at three, and it is per three-year period, so one credit a year equivalent.

North Carolina requires fifty minutes a year, not two or four hours per cycle — and it will not accept a course from a sponsor outside the NASBA registry, even though the Board expressly declines to register sponsors itself.

Michigan's state-specific hour is sole-sourced by name. The statute provides that a statewide professional association of certified public accountants approved by the department shall create the content, and the Board's rule names it: the content of the course is created by the Michigan Association of Certified Public Accountants. A licensee cannot satisfy that hour with a course written by anyone else.

Texas runs its ethics clock at a different length from its CPE clock. A four-credit board-approved ethics course every two years, inside a three-year CPE reporting period. It is the only one of the ten where the two periods differ. Texas also offers the only escape hatch we found: non-resident Texas CPAs can often meet the ethics requirement by affirming they meet their home state's requirements.

Two states where we cannot tell you the answer, and that is the finding

We will not print a figure we could not verify, and in two cases the board's own guidance and the official rule do not agree.

Georgia. The Secretary of State's official administrative code, marked current through October 2026, contains no ethics provision anywhere in the CPE chapter. The Board's own website requires four ethics credits including one specific to the laws, rules and policies of the Board. The Board's published copy of the amended rule is headed "Draft Revised CPE Rules and Regulations" and carries no effective date, while the Secretary of State's printed amendment history for the relevant rule stops in April 2016. Either the official state code has been out of date for nearly three years on a mandatory professional obligation, or the Board has been describing a rule that was never filed. We could not establish which, and until it is resolved Georgia's ethics requirement should be treated as in doubt rather than reported as four credits.

New York. The regulation requires at least four contact hours in professional ethics during the prior three calendar years, with no jurisdictional qualifier and no distinction between behavioural and regulatory ethics that we could locate. The Department's own guidance page states that licensees whose principal place of business is New York must take a New York State specific ethics course, and separately that behavioural ethics does not count as professional ethics. We checked the Counsel's Office rule index for April 2026 and found no amendment introducing either condition. Our claim is "we could not find it in the regulation", not "it is not there" — the Part 70 text is long. But if those two conditions exist only in guidance, that is a significant finding about the enforceability of a requirement New York CPAs are planning around.

What a dual-licensed CPA actually has to do

Among the five states that gate ethics on their own board — California, Michigan, Texas, Florida and, on its website, Georgia — there is no overlap at all. Each must be satisfied by its own course.

A California and Texas licensee takes the CBA Regulatory Review course on a six-year clock and the Texas board-approved ethics course on a two-year clock, and neither counts for the other. A Michigan and Florida licensee takes the MICPA-authored Michigan course and a Florida-approved ethics course. Only Texas provides relief, and only for non-residents.

The cross-market parallel is exact, and worth noting because it runs the other way. In our analysis of which US states mandate which topics for registered nurses, the problem was that a tick in a column was wrong about three states out of four. The same column, in accountancy, is wrong because the column itself is the wrong shape: the question is not whether ethics is mandated but what the state is constraining — the content, the course's approval, the sponsor's registration, or nothing beyond the subject.

Before relying on any of it, read the board's own rule. The structural reason this varies so much is that there is no national rule-maker, as our piece on who actually sets CPE for a US CPA sets out, and the units the figures are expressed in differ too, which we cover in what a CPE credit actually is. North Carolina's unusually clear statement on local content is on its own licensee page.