US CPA CPE Record Retention Runs From Four Years to Six

Ask how long a US CPA must keep CPE records and there is no national answer. Among ten large states the period runs from four years to six, one state measures it by reporting period rather than in years, one applies two different periods to two different certificates, and one of the regulators states a period in its rule that it omits from its own guidance.

The spread

Four years. Michigan requires documentation to be kept for four years after the date of applying for licence renewal, with the licensee subject to audit and liable to produce it. California's ordinary period is also four years: for a course attended, the licensee must obtain and retain a certificate of completion for four years after renewal, and the same four years applies to receipts for self-study, nano and blended learning.

Five years. New York requires documents to be retained by the licensee for not less than five years from completion of a course, and imposes the same five years on sponsors from the date each programme is completed. Pennsylvania's Board states that CPE documentation must be kept for at least five years. Georgia's official code requires records to be maintained by each licensee for five years after completion of the programme, and the Board's own version says the same. Texas's figure is five years too, though it reaches us through a sponsor registration form rather than the rule, which binds the participant as well as the sponsor.

Current year plus four. North Carolina requires CPAs to maintain records substantiating the credits claimed for the current year and each of the four prior calendar years. In practice that is five calendar years, but expressed so that the current year is always live.

Six years. Illinois requires licensees to maintain CPE records for not less than six years, and imposes the same six years on its approved sponsors. It is the longest fixed period among the ten.

Relative rather than absolute. Ohio requires documentation to be maintained until the end of the next reporting period. Because Ohio's reporting period is a fixed calendar triennium, that produces a retention obligation of between three and six years depending on when in the cycle the course was taken. Reporting itself is by sworn statement: the permit holder must provide a statement to the board under penalty of perjury.

Unverified. Florida's licensee obligation to keep certificates sits in its rule, but the rule text is published only in a format we could not read, and the Department's page does not state the period. We are not supplying a figure.

California keeps two clocks

This is the detail most likely to catch someone out. California's ordinary retention period is four years, but for its Regulatory Review course — the two-hour California-specific course required once every six years — the licensee must obtain and retain the certificate for six years after renewal.

The logic is sound: the retention period matches the recurrence. The consequence is that a California licensee has one document in their file that outlives everything else by two years, and it happens to be the document evidencing the requirement that is hardest to satisfy retrospectively, since it must come from the Board's own approved list.

Where the rule and the guidance disagree

Illinois is worth singling out, because the gap runs in the direction that disadvantages the licensee.

The rule requires records for not less than six years. The Department's own CPE frequently asked questions, revised in March 2026, says only that each licensee is responsible for maintaining records of completion, and states no period at all. A licensee relying on the guidance has no idea they are on a six-year hook.

The same document mis-cites the rule it is explaining, attributing the self-study provisions to "Section 1240.70" when the provision is section 1420.70 of a different Part entirely. A reader who follows the citation finds nothing. These are small defects, but they are in current licensee-facing guidance from the regulator, and they are the reason we keep saying to read the rule rather than the summary.

What this means for a dual-licensed CPA

You keep everything to the longest applicable period, which in practice means six years. There is no mechanism by which satisfying a four-year obligation in one state helps with a six-year obligation in another, and no state we read accepts another state's retention period as sufficient.

Two practical consequences. If you hold an Illinois licence alongside anything else, six years is your real period for all of it. And if you hold a California licence, segregate the Regulatory Review certificate, because it has its own clock.

Retention is also the obligation most likely to be the one that actually bites. Across these states, the sanctions attached to CPE non-compliance tend to arrive through the production of records rather than through the volume of learning: Ohio charges a monthly fine and places a disciplined permit holder under ongoing verification for at least two triennial reporting periods; New York's Department states that failure to produce comprehensive records in a timely manner is grounds for disciplinary action including suspension or revocation and fines. The learning is self-certified. The documents are what gets examined.

That is the same pattern we found in the UK, where the headline requirement is widely known and the retention period almost never is — see our comparison of CPD record retention periods. For the US the figure to start from is not the total but the floor and the clock, which we cover in annual minimums running from zero to forty hours, and the reason none of it is uniform is in who actually sets CPE for a US CPA. North Carolina's own statement of its period is on its licensee page.