Nobody Sets CPE for US CPAs Except the 55 State Boards

There is no such thing as the American CPE requirement. Continuing professional education for a US certified public accountant is set by the state board of accountancy that licensed them, and by nobody else. Not NASBA. Not the AICPA. Not any federal body. All three say so themselves, and the confusion that follows from not knowing it is the single biggest source of error in published material on this subject.

What NASBA actually is

The National Association of State Boards of Accountancy is an association of regulators, not a regulator. Its own account of its purpose is to advance the common interests of the Boards of Accountancy, its vision to provide those boards with the highest level of support in their regulation of the profession, and one of its stated objectives is to support the authority of the Boards of Accountancy to regulate their licensees.

On licensure NASBA is unambiguous: a CPA is a certified public accountant who is licensed by a state board of accountancy. It describes the 55 boards as the bodies that administer the Uniform CPA Examination, license more than 653,000 certified public accountants, and regulate the practice of public accountancy in the United States.

And on the diversity of the requirements, NASBA's own statement is the one to quote in any comparison: each of the 55 state boards of accountancy has its own CPE requirements for CPAs as well as rules and regulations regarding providers of CPE programs.

Fifty-five, not fifty, because the boards cover the states plus the District of Columbia, Puerto Rico, the US Virgin Islands, Guam and the Commonwealth of the Northern Mariana Islands.

What the AICPA requires, and why it is not a licensing requirement

Here is the correction that matters most, because the figure is quoted constantly without its qualification.

The AICPA does impose a CPE requirement: 120 hours or the equivalent per three-year reporting period, in force since 1 January 2001. But that is a condition of AICPA membership, and membership is voluntary. It has no bearing on whether a CPA may practise.

So a CPA who is not an AICPA member has no AICPA CPE obligation whatsoever. A CPA who is an AICPA member has two overlapping but differently defined obligations, and satisfying one does not automatically satisfy the other. "US CPAs must complete 120 hours of CPE every three years" is a statement about a trade body's membership rules dressed up as a statement about licensure.

On the licensing question the AICPA defers explicitly, in a sentence it publishes in more than one place: state boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. And more plainly still: CPE requirements vary from state to state.

The Uniform Accountancy Act is a model, and it contains no hours figure

The Uniform Accountancy Act, now in its ninth edition of July 2025 and co-published by NASBA and the AICPA, is frequently cited as though it were the law. It is a draft statute. Its own introductory comments describe it as the complete text of a statute that could be adopted in place of any accountancy law now in effect, and its preface as a single comprehensive piece of legislation that could be adopted in place of existing state laws. It has no legal force anywhere until a legislature enacts it.

What the model Act says about CPE is strikingly little. Section 6(d) requires that for renewal each licensee shall participate in a program of learning designed to maintain professional competency, and that such program of learning must comply with rules adopted by the Board. Section 4(h)(3) gives the board power to prescribe the CPE required for renewal. Section 6(b) provides that certificates are issued and renewed for periods of not more than three years.

The Act names no number. The numbers are in the companion Model Rules, whose January 2024 edition requires a minimum of 20 CPE credits during each annual period in the reporting period, an average of no fewer than 40 credits for each annual period, and an average of two ethics credits for each annual period. In the Model Rules' own comment chart that produces 40 credits for an annual period, 80 for two years and 120 for three, with ethics at two, four and six.

That is the model. It is worth knowing precisely because real states depart from it. Measured against it, no state we have examined adopts the model's formulation of an average of two ethics credits per annual period, and at least one has no annual floor at all.

There is no federal CPE requirement for a CPA licence

We should be careful about how this is stated, because it is a negative. There is no federal CPA licence, so there is no federal licence-renewal requirement and no federal authority that could publish one. We found no federal source either imposing or disclaiming such a requirement, for the straightforward reason that none exists to publish it. The point rests on the structure of the regime rather than on a citation.

What does exist federally, and gets conflated with it, is the CPE requirement in generally accepted government auditing standards. That attaches to the engagement, not the licence. An auditor performing work under GAGAS must meet its CPE requirements regardless of which state licensed them; a CPA who never performs a GAGAS engagement is subject to none of it.

The GAGAS requirement, in the 2024 revision of Government Auditing Standards issued by the Comptroller General, is that auditors should develop and maintain their professional competence by completing at least 80 hours of CPE in every two-year period, with 24 of those hours in subject matter directly related to the government environment and government auditing, 56 in subject matter that directly enhances the auditor's professional expertise to conduct engagements, and at least 20 hours in each year of the two-year period.

Two cautions. The operative verb in those provisions is "should" rather than "must", which in GAGAS terminology denotes a presumptively mandatory requirement from which departure requires documented justification. And we are deliberately not citing paragraph numbers here: the GAO-hosted HTML gives them but the PDF would not extract past an earlier paragraph, so anyone citing GAGAS formally should confirm the numbering against GAO-24-106786 directly.

Why the structure matters more than any individual figure

Three practical consequences follow from getting the architecture right.

First, a comparison table of state hours is close to useless without its sub-quotas, because the mandated subjects, the annual floors and the provider conditions differ far more than the totals do. The same lesson we drew for Australia in our analysis of why Ahpra CPD hours are not comparable across National Boards applies with greater force here, because there are 55 rule-makers rather than 15.

Second, a CPA licensed in two states is subject to both regimes in full, and the overlaps are narrower than they look. Where both states gate their ethics requirement on their own board's approval, the same course will not satisfy both.

Third, and the point most often missed by non-US training providers: a provider's accreditation status is a statement about the provider, not about the requirement. We examined the parallel question for healthcare in our piece on whether non-US organisations can hold US CE accreditation, and the accountancy answer has the same shape — the state board decides what counts, and no registry status decides it for them.

For the question of where any of this ultimately comes from, including why member bodies rather than individuals carry the international obligation, see our explainer on IES 7. NASBA's own statement of who licenses a CPA is on its getting a CPA licence page, and that is the right starting point for any state-level question.