Illinois CPAs Owe an Hour of Training That Is Not in the Accounting Act

An Illinois CPA has a continuing education obligation that does not appear in the Illinois Public Accounting Act, does not appear in the CPA rules, and applies whether or not their profession has a continuing education requirement at all. It is one hour of sexual harassment prevention training per renewal cycle, and it comes from somewhere else entirely.

Where it comes from

The authority is not the accountancy legislation. It is a provision of the statute governing the Department of Professional Regulation generally, at 20 ILCS 2105/2105-15.5, and the Department's own continuing education page cites it directly.

What the Department says about its scope is the part worth knowing: the requirement applies to any individual, non-business, licence holder under any Act the Department administers, even if that profession has no continuing education requirement. It also applies on reinstatement or restoration.

And the Department is unusually direct about why it cannot be waived or negotiated: these requirements are established by law, not by Department policy.

Approved providers include the licensee's own employer, the Illinois Department of Human Rights, or a continuing education provider authorised under a Department-administered Act. The hour may be counted toward the minimum credit hours required for the profession, so for a CPA it sits inside the 120 rather than on top.

Why a CPA would never find it

Because it is not where anyone would look. The Public Accounting Act section on continuing education sets no hours at all — it requires evidence of completing continuing professional education as prescribed by Department rules, permits the Department to prescribe rules for the content, duration and organisation of courses, and exempts CPAs from the requirement for their first renewal after original licensure. The accountancy rule itself, which does carry the numbers, mentions professional ethics but not sexual harassment prevention.

So a licensee who reads the Act and the accountancy rule has read both of the documents a careful person would read, and has still missed a mandatory hour.

The Department's own CPA continuing education guidance does mention it. Which brings us to the state of that guidance.

Two defects in Illinois's current CPE guidance

The Department's frequently asked questions on CPA continuing education, revised in March 2026, has two problems that both work against the licensee.

It mis-cites its own rule. The document gives the authority for self-study continuing education as Section 1240.70 of the CPA Rules. The provision is section 1420.70, in a different Part of the Administrative Code entirely. Part 1240 is something else. A licensee who follows the citation finds nothing, and the document never cites the correct Part anywhere we could see.

It omits the retention period. The rule requires licensees to maintain CPE records for not less than six years — the longest fixed period of any state we examined. The guidance says only that each licensee is responsible for maintaining records of completion, and states no period at all. So a licensee relying on the Department's own guidance has no idea they are on a six-year hook, and Illinois is precisely the state where that matters most. We set out the full spread in our piece on CPE record retention by state.

What Illinois's actual CPE requirement looks like

Worth setting out, because it is unusual in two other respects.

The rule requires 120 hours every three-year renewal period, including at least four hours covering the subject of professional ethics. Illinois expressly lists both behavioural ethics and regulatory ethics as eligible fields, which puts it at the permissive end: New York's Department, by contrast, states that behavioural ethics does not count as professional ethics. Same nominal four hours, opposite treatment of the same course.

And Illinois sets no annual minimum whatsoever. It is the only state we examined with a multi-year total and no floor inside it, so a licensee may lawfully complete nothing in years one and two and all 120 hours in year three. That makes Illinois the most flexible regime of the ten and, for anyone also licensed in a state with an annual floor, the flexibility is worthless — they are governed by the stricter clock in practice. The full range runs from zero to forty, as our piece on annual minimums sets out.

In exchange for that flexibility Illinois imposes the most elaborate cap structure we found: no more than 60 hours of non-interactive self-study, no more than 80 hours of interactive and non-interactive self-study combined, no more than 60 hours for presentation or preparation time, no more than 30 hours for authorship, no more than 60 hours from all non-verifiable activities combined, and no more than 24 hours of personal development.

That last pair is distinctive. Capping by verifiability is an axis no other state we examined uses, and a 24-hour cap on personal development is 20% of the total — a tighter constraint on soft subjects than a 50% technical floor, applied to a narrower category.

The timetable is a fixed triennium expiring 30 September, the same for every licensee rather than anchored to an anniversary, and all CPE must be completed in the three years preceding expiration. Illinois also licenses its own CPE sponsors while separately accepting NASBA Registry members, so Registry status is sufficient but not necessary.

The general point

A professional obligation does not have to live in the professional statute. Illinois is the clearest example we found, but the pattern recurs: Michigan's hours are in its Occupational Code rather than its board rules, Florida's range and percentages are in statute while the familiar figures are in the rule, and Georgia's requirement currently depends on which of two documents you read.

Which is a reason to check the regulator's general licensing provisions and not only the profession's own, and a reason to treat a board's frequently asked questions as a starting point rather than an answer. The Department's own continuing education page, which carries the sexual harassment provision and its citation, is published by IDFPR, and the structural reason these requirements vary so much is covered in who actually sets CPE for a US CPA.