Regulatory | Advocacy | Talent Pipeline

The Changing Landscape of CPA Licensure: What It Means for Colorado CPAs

Momentum to modernize CPA licensure has gained traction in 2025 nationwide, with fourteen states enacting laws to date, signed by governors, and more in process that introduce an alternative licensure pathway. These new laws allow candidates to become CPAs with a Bachelor’s degree (typically 120 credit hours) and two years of relevant experience, alongside passing the Uniform CPA Exam. Importantly, these states have retained the traditional routes, including 150 credit hours + 1 year of experience or a Master’s degree + 1 year of experience.

For Colorado CPAs, understanding these developments is essential for career planning and maintaining multistate practice flexibility. While all states aim to broaden access, their approaches vary. Some states have defined educational qualifications by retaining specific credit hour references, while others have shifted to degree-based requirements, including specificity around majors or concentrations.

A Broader Strategy to Strengthen the CPA Pipeline

This movement is part of a broader strategy to strengthen the CPA talent pipeline. Amid rising education costs and competition for talent, the 150-hour requirement has been a highly debated barrier, adding both time and financial burden. A 2023 report from the Center for Audit Quality found it was the third most common reason non-accounting majors gave for not pursuing accounting, behind lack of interest and more attractive starting salaries elsewhere.

As the profession works to tell a more compelling story about the meaningful work CPAs do, improve starting pay, and showcase purpose-driven careers, state societies, like the Colorado Society of CPAs (COCPA) are also advocating for licensure modernization to expand access while preserving the credential’s integrity.

This approach has general support from COCPA members. In a 2024 COCPA member survey, 85% of respondents supported changes to the licensure model to encourage a pipeline of future CPAs, emphasizing the importance of maintaining professional rigor and protecting mobility across states. These tenants have shaped COCPA’s position and actions in the national conversation.

National Acceptance of Alternative Pathways

The Uniform Accountancy Act (UAA), jointly developed by the AICPA and NASBA, was approved for update in May 2025 to reflect evolving perspectives on CPA licensure. After a thorough stakeholder driven process that began in September 2024, the revised UAA now formally recognizes three pathways to licensure:

  1. Bachelor’s Degree + 2 Years of Experience + CPA Exam
  2. Bachelor’s Degree + 30 Additional Credit Hours + 1 Year of Experience + CPA Exam
  3. Master’s Degree + 1 Year of Experience + CPA Exam

The Colorado Society of CPAs (COCPA) was among many organizations that provided input throughout the UAA process. 

While not imposing uniformity, the UAA serves as model legislation for states with a goal to reduce regulatory fragmentation while preserving state autonomy. Because many states currently reference the UAA or rely on its definitions for granting mobility privileges for out of state CPAs, the updates to the model law helps minimizes disruption to interstate practice, particularly in jurisdictions that have yet to pass their own legislation.

Colorado’s Legislative Timeline and Next Steps

While Colorado has not yet adopted the alternative licensure pathway, at its April 2025 meeting, the COCPA Board of Directors voted to support future legislation that would align the Colorado Accountancy Act with the UAA’s revised licensure pathways.

With the next Colorado legislative session beginning in January 2026, the COCPA Board of Directors has appointed a Licensure Modernization Taskforce to provide leadership and insight through the legislative process. The taskforce will be chaired by Immediate Past Chair Toby Clary, CPA and will include members selected for their diverse representation and strategic presence in legislative districts with key policymaker influence. This taskforce will work closely with COCPA staff, legislative consultants, and stakeholders to ensure that the Colorado Accountancy Act is updated thoughtfully.  

The COCPA is working closely with the State Board of Accountancy, a key stakeholder, to align efforts and ensure both the profession's interests and the public interest are fully represented throughout this change. The State Board is next scheduled to meet on June 18, 2025, and further discussion on this topic is anticipated.

What This Means for Colorado CPA Candidates and Current Licensees

CPA Candidates in Colorado

Until legislative changes are finalized in Colorado, CPA candidates must continue to meet the current licensure requirements:

  • 150 credit hours of education
  • One year of qualified experience
  • Successful completion of the Uniform CPA Exam and the ethics exam

While some candidates may be enticed to become licensed in a state with a new Bachelor's + 2 years Experience pathway, its important for candidates to consider licensure requirements in the state where they plan to reside or establish their principal place of business.

For Colorado Licensed CPAs

No major disruption is expected for CPAs currently licensed in Colorado and practicing within the state while licensure changes remain pending.

Interstate mobility for Colorado CPAs into other jurisdictions is also expected to remain intact; however, several uncertainties could still lead to disruption. Questions remain about how states will implement newly adopted automatic mobility provisions, how State Boards of Accountancy will interpret licensure changes where mobility decisions fall under their authority, and how NASBA’s National Qualification Appraisal Service (NQAS) will evaluate substantial equivalency under the recently updated UAA, particularly in states that continue to rely on NQAS to support mobility privileges.

For CPAs from Other States Serving Colorado Clients

Colorado’s practice privilege rules reference the UAA and NASBA’s National Qualification Appraisal Service (NQAS) to determine substantial equivalency, the basis for allowing CPAs to practice in Colorado without holding a Colorado license. With the latest edition of the UAA now recognizing new licensure pathways, CPAs licensed in states that have adopted these changes may still practice in Colorado, even though Colorado has not yet formally adopted these pathways, provided that NQAS deems those states substantially equivalent. We are actively monitoring how NQAS will interpret and respond to these recent state law changes under the updated UAA framework.

Stay Informed and Engaged

With January 1, 2026 targeted by many states for licensure changes, the months ahead are critical. COCPA encourages CPAs to stay informed on licensure and mobility rules in states where they serve clients and rely on practice privilege. In some cases, obtaining a reciprocal license may be a prudent step during this transitional period. Depending on the scope and nature of the work performed, consulting legal counsel may be advisable to assess individual risks and determine the most appropriate course of action.

Maintaining your COCPA membership is vital as it ensures we can continue this important work on behalf of the profession. In addition, contributions to the CPA Political Action Committee (CPA PAC) help us build relationships with legislative champions who support policies that protect and advance the CPA license.

COCPA will continue to provide updates, resources, and advocacy as licensure modernization takes shape across the country.

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Alicia Gelinas