Passing SB26-076 marked a major step forward for CPA licensure in Colorado. Writing the Rules is where the rubber meets the road for CPA candidates and employers.

Colorado's new pathways to CPA licensure take effect January 1, 2027. Between now and then, the Colorado State Board of Accountancy is developing the Rules to implement SB26-076, including how applications will be reviewed, what coursework will be required, and how out-of-state CPAs can practice in Colorado. That work is happening right now, and COCPA members are helping shape the conversation.

A quick refresher on SB26-076

Governor Polis signed SB26-076 into law on May 4, 2026, after the bill cleared the Senate unanimously and the House with strong bipartisan support. The legislation expands how future CPAs can enter the profession by creating additional education and experience combinations that satisfy the requirements for certification, beginning January 1, 2027. You can read more about SB26-076 in an earlier COCPA blog post here. 

Where the rulemaking stands and what happens next

On August 28, 2026, the Colorado State Board of Accountancy released its redlined version of the proposed Rules for public comment. On September 9, 2026, the Board held a stakeholder session to gather feedback on that draft — an important step in Colorado's rulemaking process. Twenty-five members of the public participated.

Ahead of the stakeholder session, COCPA’s Licensure Taskforce met to digest and make recommendations on the proposed Rules. Overall, COCPA was pleased to see the Board’s thoughtful work to implement SB26-076 and that the proposed Rules reflect several of the initial recommendations COCPA submitted in its May 2026 letter to the Board. The current round of 13 comments, outlined in COCPA’s September 9 letter to the State Board of Accountancy, builds on that progress and focuses on areas where additional clarity or refinement could support successful implementation. Each comment was identified as high, moderate, or low priority to help the Board distinguish issues COCPA believes should be addressed now from those that can be considered later.

At the heart of COCPA’s comments was a focus on making the Rules a clear and workable roadmap for applicants from the start:

“…We believe clear and consistent Rules are imperative as SB26-076 takes effect January 1, 2027. Clarity will help stakeholders understand and benefit from the new licensure pathways and enable NASBA, as the Board's application processing agent, to administer the requirements consistently. Addressing these issues now will reduce ambiguity, minimize Board referrals and unnecessary application delays, and support successful implementation…”

At its meeting on October 21, 2026, the Board is expected to weigh stakeholder feedback and revise the draft Rules. If the revised draft isn't ready for adoption, the process continues: the Board will make further edits and release another version of the Rules for public comment before holding a vote.

Either way, the timeline is tight — the new pathways become available to applicants on January 1, 2027.

Turning member feedback into recommendations: the high-priority issues

COCPA's input wasn't assembled in a vacuum. The recommendations were developed with insight from a Licensure Taskforce made up of COCPA members.  The Colorado educator community was invited to share feedback for the Licensure Taskforce to weigh as it shaped COCPA's recommendations. Educators sit closest to the coursework provisions in these Rules — what counts as accounting or business credit, how concentrations are defined, when a student in a combined program becomes eligible to sit —  and their perspective shaped several of the comments in the letter.

COCPA’s comments focused on aligning the Rules with the intent of SB26-076 while reflecting the practical realities facing educators, candidates, practitioners, and employers. They also considered the increasingly interstate nature of accounting education, licensure, and practice, with an emphasis on preserving flexibility as candidates pursue licensure and build their careers.

With those considerations in mind, COCPA identified several high-priority issues in its written comments. Several COCPA members reinforced those recommendations through verbal testimony at the September 9 stakeholder meeting, including on the following issues:

• Exam eligibility for candidates enrolled in combined and dual-degree programs. The draft appropriately removes the former 120-semester-hour eligibility requirement, consistent with the statute's shift to a degree-based standard. The proposed Rules now tie exam eligibility to the formal conferral of a baccalaureate degree, but in doing so, language was removed that addresses students in combined or dual-degree programs where the bachelor's degree may not be conferred until later in the program. COCPA recommended preserving and updating that provision so candidates who have completed all requirements for a baccalaureate degree can be eligible to sit for the CPA Exam, even if the institution does not formally confer the degree until later in the combined or dual-degree program.
• Practice privilege and mobility (Rule 1.14). COCPA's top alignment priority. The letter recommends "updating Rule 1.14 to conform to the practice privilege requirements established by SB26-076" and dropping references to the prior Uniform Accountancy Act (UAA) substantial equivalency and NASBA National Qualification Appraisal Service (NQAS) frameworks. It also supplies replacement language with two built-in guardrails: at the time of initial licensure or certification, out-of-state CPAs must have passed the Uniform CPA Examination and earned a baccalaureate degree from an accredited college or university.
• Two requirements appear to have been removed unintentionally. The three-semester-hour U.S. GAAS coursework requirement was struck from the education requirements for certification but survives in the educational requirements for examination. That mismatch, the letter warns, "could cause disparity between candidates that take the exam in Colorado versus those that take the exam in another state and transfer exam scores into Colorado to qualify for eligibility." Separately, the nine-semester-hour cap on credits in any single subject area appears to have been removed as part of the broader cleanup of references to the previous 150-hour requirement. COCPA recommended restoring both provisions to maintain consistency. 

Advocacy powered by members 

This work demonstrates why membership matters. COCPA's ability to represent the profession starts with members who share their expertise, raise concerns, and help us understand how changes will affect individual stakeholders and the profession as a whole. Our role doesn't end when legislation passes; we remain engaged through rulemaking and implementation, bringing member perspectives to the table, identifying potential unintended consequences, communicating developments, and advocating for practical solutions. As Colorado prepares for the new licensure pathways to take effect, COCPA remains committed to keeping members informed, creating opportunities for their perspectives to be heard, and ensuring the profession has a strong voice in the decisions shaping its future.