2025 Pennsylvania Consolidated & Unconsolidated Statutes
Act 27 - CPA LAW - OMNIBUS AMENDMENTS
Session of 2025
No. 2025-27
SB 719
AN ACT
Amending the act of May 26, 1947 (P.L.318, No.140), entitled "An act relating to the practice of public accounting; providing for the examination, education and experience requirements for certification of certified public accountants and for the licensing of certified public accountants, public accountants and firms; requiring continuing education and peer review; providing for the organization and ownership of firms and for the procedures and grounds for discipline and reinstatement of licensees; prescribing the powers and duties of the State Board of Accountancy and the Department of State; providing for ownership of working papers and confidentiality; regulating the professional responsibility of licensees; defining unlawful acts and acts not unlawful; providing penalties; and repealing existing laws," further providing for definitions, for general powers of the board, for examination and for requirements for issuance of certificate; repealing provisions relating to practice in this Commonwealth by individuals under substantial equivalency; further providing for practice outside this Commonwealth under substantial equivalency and for practice by firms and unlicensed entities under substantial equivalency; providing for practice in this Commonwealth by individuals under automatic mobility; and further providing for licenses to practice, for licensing of firms, for grounds for discipline, for reinstatement and for unlawful acts.
The General Assembly of the Commonwealth of Pennsylvania hereby enacts as follows:
Section 1. Section 2 of the act of May 26, 1947 (P.L.318, No.140), known as the CPA Law, is amended by adding definitions to read:
Section 2. Definitions.--The following words and phrases when used in this act shall have the meanings ascribed to them in this section unless the context clearly indicates otherwise:
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"Automatic mobility." The ability of a certified public accountant who is actively certified and licensed to practice public accounting in another state, is in good standing and whose principal place of business is outside of this Commonwealth to immediately have practice privileges in this Commonwealth without obtaining a license, giving notice or paying a fee to the board, but is subject to the jurisdiction and discipline authority of the board.
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"Post-secondary." Approved credits earned by an individual through:
(1) an accredited college or university;
(2) an articulation agreement;
(3) advanced placement courses or a dual enrollment program prior to enrolling in a public accounting program; or
(4) another means approved by the board.
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Section 2. Sections 3(a)(5)(v) and (vi) and (b) and 3.1(c) of the act are amended to read:
Section 3. General Powers of the Board.--(a) The Board shall have the power:
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(5) To:
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(v) revoke, suspend or limit the right of a person to practice under section [5.2 or] 5.4 or 5.5 of this act;
(vi) censure or publicly reprimand a person practicing under section [5.2 or] 5.4 or 5.5; and
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(b) The board shall not require a photograph or character reference as part of an application for a certificate of certified public accountant[.] unless the character reference is necessary to comply with 63 Pa.C.S. § 3113(c) (relating to consideration of criminal convictions).
Section 3.1. Examination.--
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(c) [Subject to such regulations as the board may adopt governing reexaminations, a candidate shall be entitled to retake the examination.] An applicant may take each part of the examination in any order and retake a part of the examination that the applicant did not pass. The applicant shall receive credit for each part of the examination the applicant passed if the applicant passes all parts of the examination within a rolling thirty-month period beginning on the date the applicant passes one part of the examination. If the applicant does not pass all parts within the thirty-month period, credit for the earliest part of the examination passed shall expire, and a new rolling thirty-month period shall begin on the date the next passing score is released. This cycle of rolling thirty-month periods and credit expirations shall continue until all parts are passed within a single thirty-month period. The board may extend the thirty-month period or the term of an applicant's conditional examination credits if the applicant demonstrates that the failure to pass or the expiration of credits was due to circumstances beyond the applicant's control.
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Section 3. Section 4.2(b), (b.1), (c), (d) and (e) of the act are amended and the section is amended by adding a subsection to read:
Section 4.2. Requirements for Issuance of Certificate.--* * *
(b) Except as provided under subsection (b.1), before an individual may take the examination, the board shall be satisfied that the individual meets all of the following:
(1) [has] Has attained eighteen years of age[;].
(2) [is] Is of good moral character[; and]. In assessing the moral character of an applicant with a criminal conviction, the board shall conduct an individualized assessment in accordance with 63 Pa.C.S. § 3113 (relating to consideration of criminal convictions).
(3) [has] Has graduated with:
(i) a baccalaureate or higher degree from a college or university accredited by a nationally recognized accrediting agency recognized by the United States Department of Education, or a college or university approved by the board, and completed a total of one hundred fifty semester credits of post-secondary education, including at least a total of twenty-four semester credits of accounting and auditing, business law, economics, technology, finance or tax subjects of a content satisfactory to the board and an additional twelve semester credits in accounting and auditing subjects or tax subjects of a content satisfactory to the board, not necessarily as part of the individual's undergraduate or graduate work;
(ii) a baccalaureate degree from a college or university accredited by a nationally recognized accrediting agency recognized by the United States Department of Education, or a college or university approved by the board, and completed at least a total of twenty-four semester credits, which credits shall be in accounting and auditing, business law, economics, technology, finance or tax subjects of a content satisfactory to the board, not necessarily as a part of his undergraduate work; or
(iii) a Master's Degree or other post-graduate degree from a college or university accredited by a nationally recognized accrediting agency recognized by the United States Department of Education, or a college or university approved by the board, and completed at least a total of twenty-four semester credits, which credits shall be in accounting and auditing, business law, economics, technology, finance or tax subjects of a content satisfactory to the board, not necessarily as part of his undergraduate or graduate work.
(b.1) An individual may take the examination on or after the effective date of this subsection if the board is satisfied that the individual meets the requirements under subsection (b)(1) and (2) and has:
(1) graduated with a baccalaureate degree; or
(2) completed [a total of] at least one hundred twenty semester credits of post-secondary education.
[(c) Before an individual who takes the examination under subsection (b)(3)(ii) or (iii) may be issued a certificate, the individual must also satisfy the education requirement in subsection (b)(3)(i).]
(d) Before an individual may be issued a certificate, the board shall be satisfied that the individual has completed [at least one year of] necessary experience that:
(1) was completed within sixty months preceding the date of application for a certificate;
(2) included providing any type of service or advice involving the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, which were gained through employment in government, industry, academia or public practice;
(3) was of a caliber satisfactory to the board; and
(4) was verified by an individual with a current license to practice public accounting as a certified public accountant or public accountant in this Commonwealth or another state or a substantially equivalent licensed individual from a foreign country or be verified using NASBA's Experience Verification Service.
[(e) The following requirements may be complied with instead of the otherwise applicable provisions of subsections (b), (c) and (d):
(1) An individual who took the examination before December 31, 2011, but did not pass at least one part taken before that date, may not be issued a certificate until the individual:
(i) has satisfied the education requirement in subsection (c), if applicable; and
(ii) has completed at least one year of experience described in subsection (d)(2), (3) and (4) within one hundred twenty months preceding the date of application for a certificate.
(2) An individual who passed at least one part of the examination taken before December 31, 2011, pursuant to subsection (b)(3)(ii), may be issued a certificate before or after December 31, 2011, without satisfying the education requirement in subsection (c), but not until the individual has completed at least two years of experience that satisfies the requirements in subsection (d)(2), (3) and (4). The experience may be completed within one hundred-twenty months preceding the date of application for a certificate.
(3) An individual who passed at least one part of the examination taken before December 31, 2011, pursuant to subsection (b)(3)(iii), may be issued a certificate before or after December 31, 2011, without satisfying the education requirement in subsection (c) and may complete the one year of experience required by subsection (d) within one hundred twenty months preceding the date of application for a certificate.]
(f) After passage of the examination, a certificate may be issued to an individual:
(1) satisfying the educational requirements of subsection (b)(3)(i) or (iii) with at least one year of qualifying experience; or
(2) satisfying the educational requirements of subsection (b)(3)(ii) with at least two years of qualifying experience.
Section 4. Section 5.2 of the act is repealed:
[Section 5.2. Practice in this Commonwealth by Individuals under Substantial Equivalency.--(a) A person may practice public accounting in this Commonwealth under substantial equivalency as provided in this section and section 5.4. Any determination as to whether substantial equivalency exists with respect to a state or individual for purposes of this act shall be consistent with any determination as to substantial equivalency with respect to that state or individual made by the National Association of State Boards of Accountancy National Qualification Appraisal Service.
(b) The following apply to practice in this Commonwealth under substantial equivalency:
(1) Notwithstanding any other provision of this act, an individual whose principal place of business is not in this Commonwealth and who has a valid certificate or right to practice public accounting from a state that is substantially equivalent shall be presumed to have qualifications substantially equivalent to the Commonwealth's requirements and shall have all the privileges and obligations of a licensee of the Commonwealth without the need to obtain a certificate or license under this act.
(2) Notwithstanding any other provision of this act, an individual whose principal place of business is not in this Commonwealth and who has a valid certificate or right to practice public accounting from a state that is not substantially equivalent shall be presumed to have qualifications substantially equivalent to the Commonwealth's requirements and shall have all the privileges and obligations of a licensee of the Commonwealth without the need to obtain a certificate or license if there is substantial equivalency as to the individual. In determining whether substantial equivalency exists as to an individual, the order in which the individual satisfied the experience, education and examination requirements shall be disregarded.
(3) The exercise by an individual of the right to practice in this Commonwealth under this section constitutes:
(i) sufficient contact with this Commonwealth for the exercise of personal jurisdiction by the board and the courts of this Commonwealth over the individual in any action or proceeding arising out of acts or omissions by the individual;
(ii) consent by the individual to the personal and subject matter jurisdiction and disciplinary authority of the board;
(iii) an agreement by the individual to comply with the provisions of this act and regulations promulgated by the board; and
(iv) consent by the individual to the appointment of the board of accountancy or other regulatory authority of the state in which the principal place of business of the individual is located as the agent upon which process may be served in any action or proceeding by the board against the individual.
(4) An individual who exercises the right to practice under this section shall be subject to disciplinary action in this Commonwealth for any act or omission that would subject the holder of a Pennsylvania certificate or license to disciplinary action.
(5) An individual who passed the Uniform CPA Examination and holds a valid license to practice public accounting issued by any other state on or before December 31, 2011, may be exempt from the education requirements in section 4.2(b)(3)(i) and (c) of this act for purposes of this section.
(6) If the board imposes discipline on an individual exercising the right to practice under this section, the board shall, as soon as practicable, notify the board of accountancy or other regulatory authority in each state where the board has learned during the disciplinary process that the individual has been granted a certificate or license to practice public accounting of the imposition of the discipline. If the order imposing discipline is appealed or stayed, the board shall send a subsequent notice to each regulatory authority advising of the filing of the appeal or entry of the stay. As an alternative to sending the notices to each regulatory authority, the board may send the notices instead to a multistate enforcement information network maintained at the time by AICPA or NASBA. The board may furnish investigative information and the hearing record relating to the disciplinary proceeding to such other regulatory authorities upon request.
(7) An individual exercising the right to practice under this section may identify the fact that the individual practices with a partnership, corporation or other association and may use its name even if the partnership, corporation or other association is not a licensee.
(8) An individual practicing under this section or a firm or qualified unlicensed entity practicing under section 5.4 may provide professional services in this Commonwealth in the same manner as a licensee, including without limitation, in person or by mail, telephone or electronic means.
(9) The board shall not require a filing or payment of a fee by an individual, firm or qualified unlicensed entity in connection with practicing under this section or section 5.4.]
Section 5. Sections 5.3 heading and (a) introductory paragraph and 5.4 heading, (a) introductory paragraph and (b)(1) of the act are amended to read:
Section 5.3. Practice outside this Commonwealth under [Substantial Equivalency] Automatic Mobility.--(a) A licensee who practices public accounting in another jurisdiction under [substantial equivalency] automatic mobility shall be subject to disciplinary action in this Commonwealth for an act or omission in the other jurisdiction if the act or omission:
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Section 5.4. Practice by Firms and Unlicensed Entities under [Substantial Equivalency] Automatic Mobility.--(a) A firm may practice public accounting in this Commonwealth through an individual who is not a licensee if the individual has the right to practice in this Commonwealth under section [5.2] 5.5 of this act. The exercise by a firm of the right to practice through such individuals under this subsection constitutes an agreement by the firm:
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(b) A qualified unlicensed entity may practice public accounting in this Commonwealth through an individual who:
(1) has the right to practice in this Commonwealth under section [5.2] 5.5 of this act; or
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Section 6. The act is amended by adding a section to read:
Section 5.5. Practice in this Commonwealth by Individuals under Automatic Mobility.--(a) An individual may practice public accounting in this Commonwealth under automatic mobility as provided under section 5.4 and this section.
(b) The following apply to practice in this Commonwealth under automatic mobility:
(1) Notwithstanding any other provision of this act, an individual whose principal place of business is not located in this Commonwealth and has a valid certificate or right to practice public accounting from another state shall have all the privileges and obligations of a licensee of the Commonwealth without the need to obtain a certificate or license under this act if the individual:
(i) has:
(A) obtained a baccalaureate degree and completed a total of at least one hundred fifty semester credit hours or a higher degree from an accredited college or university and includes credits in accounting, auditing, business law, economics, technology, finance, tax subjects or any other courses approved by the board;
(B) passed the examination; and
(C) attained at least one year of experience prior to certification; or
(ii) has:
(A) obtained a baccalaureate degree from an accredited college or university that includes credits in accounting, auditing, business law, economics, technology, finance, tax subjects or any other courses approved by the board, even if the credits are not part of the individual's baccalaureate degree;
(B) passed the CPA examination; and
(C) attained at least two years of experience prior to certification.
(2) The exercise by an individual to practice in this Commonwealth under this section constitutes:
(i) Sufficient contact with this Commonwealth for the exercise of personal jurisdiction by the board and the courts of this Commonwealth over the individual in any action or proceeding arising out of acts or omissions by the individual.
(ii) Consent by the individual to the personal and subject matter jurisdiction and disciplinary authority of the board.
(iii) An agreement by the individual to comply with this act and regulations promulgated by the board under this act.
(iv) Consent by the individual to the appointment of the board or other regulatory authority of the state in which the principal place of business of the individual is located as the agent upon which process may be served in any action or proceeding by the board against the individual.
(3) An individual who practices public accounting under this section shall be subject to disciplinary action in this Commonwealth for any act or omission that would subject the holder of a Pennsylvania certificate or license to disciplinary action.
(4) If the board imposes discipline on an individual exercising the right to practice under this section, the board shall, as soon as practicable, notify the board of accountancy or other regulatory authority in each state where the board has learned during the disciplinary process that the individual has been granted a certificate or license to practice public accounting of the imposition of the discipline. If the order imposing discipline is appealed or stayed, the board shall send a subsequent notice to each regulatory authority advising of the filing of the appeal or entry of the stay. As an alternative to sending the notices to each regulatory authority, the board may send the notices instead to a multistate enforcement information network maintained at the time by AICPA or NASBA. The board may furnish investigative information and the hearing record relating to the disciplinary proceeding to other regulatory authorities upon request.
(5) An individual practicing public accounting under this section may identify that the individual practices with a partnership, corporation or other association and may use the name even if the partnership, corporation or other association is not a licensee.
(6) An individual practicing under this section or a firm or qualified unlicensed entity practicing under section 5.4 may provide professional services in this Commonwealth in the same manner as a licensee, including, without limitation, in person or by mail, telephone or electronic means.
(7) An individual whose principal place of business is not located in this Commonwealth and who holds a valid active license as a certified public accountant from a state that is valid in this Commonwealth as of the effective date of this clause shall continue to have all of the practice privileges of a licensee in this Commonwealth without the need to obtain a license under section 4.2 or 5.
(8) The board shall not require notice or filing or payment of a fee by an individual, firm or qualified unlicensed entity in connection with practicing under section 5.4 or this section.
Section 7. Section 8.2 of the act is amended by adding a subsection to read:
Section 8.2. Licenses to Practice.--* * *
(d.1) A licensee practicing under reciprocity under section 5 or 5.1 or automatic mobility shall only be required to comply with the continuing education requirements of the jurisdiction where the licensee's principal license is active and renewed, which is the state of the licensee's principal place of business. If the licensee's principal place of business is located in a state that has no continuing education requirements for renewal of a license, the licensee shall comply with all continuing education requirements for renewal under this act and the board's regulations.
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Section 8. Sections 8.8(a)(3), 9.1(a) introductory paragraph, (1) and (17), 9.2(e) and 12(a), (c), (f) introductory paragraph, (l.1), (l.2), (m), (n), (q) and (r) of the act are amended to read:
Section 8.8. Licensing of Firms.--(a) The following shall apply:
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(3) A new firm must designate a licensee of this Commonwealth, or for a firm which practices pursuant to section 5.4 of this act, a licensee of another state who meets the requirements under section [5.2] 5.5 of this act, who is responsible for the proper registration of the firm and who identifies that individual to the board.
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Section 9.1. Grounds for Discipline.--(a) In accordance with the procedure provided in section 9 of this act, the board may revoke, suspend, limit or otherwise restrict the certificate of a certified public accountant or the registration of a public accountant, may revoke, suspend, limit or otherwise restrict any license issued under this act, may censure or publicly reprimand the holder of any certificate, registration or license, may require completion of general or a specific number of continuing professional education courses or may require more frequent peer review or other remedial action, or may revoke, suspend or limit the right of an individual to practice under section [5.2] 5.5 of this act or censure or publicly reprimand an individual practicing under section [5.2] 5.5 of this act for any one or any combination of the following causes:
(1) Fraud or deceit in obtaining:
(i) a certificate of certified public accountant;
(ii) registration under this act;
(iii) a license to practice under this act; or
(iv) a determination that substantial equivalency or automatic mobility exists with respect to an individual.
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(17) An act or omission by a licensee in another jurisdiction under substantial equivalency or automatic mobility that subjects the licensee to discipline in the other jurisdiction.
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Section 9.2. Reinstatement.--* * *
(e) Upon application in writing and after hearing pursuant to notice, the board may reinstate or modify the suspension of an individual's right to practice under section [5.2] 5.5 of this act which has been revoked or suspended.
Section 12. Unlawful Acts.--(a) Except as provided in sections [5.2 and] 5.4 and 5.5 of this act, it is unlawful for any person to hold himself out as or otherwise use the title or designation "certified public accountant," or the abbreviation "CPA," or any other title, designation, words, letters or abbreviation tending to indicate that the person is a certified public accountant or engaged in the practice of public accounting unless the person has received or has been notified in writing by the board that he has qualified to receive a certificate of certified public accountant issued by this Commonwealth, which is not revoked or suspended.
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(c) Except as provided in sections [5.2 and] 5.4 and 5.5 of this act, it is unlawful for any partnership, corporation or other association to hold itself out as or otherwise use the title or designation "certified public accountant" or "public accountant" or the abbreviation "CPA" or "PA," or any other title, designation, words, letters or abbreviation tending to indicate that the partnership, corporation or other association is composed of or includes certified public accountants or public accountants unless the partnership, corporation or other association holds a current license under section 8.8 of this act.
(f) Except as provided in this subsection, in sections [5.2 and] 5.4 and 5.5 of this act or in subsections (a) and (c), it is unlawful for any person to use a title that includes the word "certified" as a part thereof, or any other title or designation likely to be confused with "certified public accountant," or any title or designation implying or connoting accreditation by any jurisdiction for the practice of any type of bookkeeping, accounting, auditing, tax or other professional practice related thereto, or to use any abbreviation of such title or designation. It is not a violation of this subsection for an individual:
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(l.1) It is unlawful for any person to sell or offer to sell or fraudulently obtain, furnish or procure any certificate, registration, license or determination of substantial equivalency or automatic mobility under the provisions of this act or cause or aid or abet another person to do so.
(l.2) Except as provided in sections [5.2 and] 5.4 and 5.5 of this act, it is unlawful for any person that is not a licensee to sign, affix a firm name to or otherwise issue any:
(1) report; or
(2) opinion, certificate or other communication respecting compliance with conditions established by law or contract, including, but not limited to, statutes, ordinances, regulations, grants, loans and appropriations, together with any wording, accompanying or contained in such opinion, certificate or other communication that indicates that the person is composed of or employs:
(i) accountants or auditors; or
(ii) persons having expert knowledge in accounting or auditing.
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(m) Except as provided in sections [5.2 and] 5.4 and 5.5 of this act, it is unlawful for any individual who is not a licensee to sign or affix his name or any trade or assumed name used by him in his profession or business to or otherwise issue any:
(1) report; or
(2) opinion, certificate or other communication respecting compliance with conditions established by law or contract, including, but not limited to, statutes, ordinances, regulations, grants, loans and appropriations, together with any wording accompanying or contained in such opinion, certificate or other communication, which indicates:
(i) that he is an accountant or auditor; or
(ii) that he has expert knowledge in accounting or auditing.
The provisions of this subsection shall not prohibit any officer, employe, partner, or principal of any organization from affixing his signature to any communication in reference to the affairs of the organization with any wording designating the position, title, or office which he holds in the organization, nor shall the provisions of this subsection prohibit any act of a public official or public employe in the performance of his duties as such.
(n) Except as provided in sections [5.2 and] 5.4 and 5.5 of this act, it is unlawful for any person not a licensee to hold himself or itself out to the public as an "auditor" or as an "accountant and auditor." This subsection shall not prohibit any officer, employe, partner, or principal of any organization from describing himself by the position, title or office he holds in the organization, nor shall this subsection prohibit any action of a public official or public employe in the performance of his duties as such.
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(q) Except as provided in sections [5.2 and] 5.4 and 5.5 of this act, it is unlawful for any person not a licensee to engage in the practice of public accounting in this Commonwealth.
(r) Except as provided in sections [5.2 and] 5.4 and 5.5 of this act, it is unlawful for any person not a licensee to prepare financial information that is accompanied by a letter or other text that does not comply with section 13(c) of this act.
Section 9. This act shall take effect immediately.
APPROVED--The 30th day of June, A.D. 2025.
JOSH SHAPIRO
