On October 21, 2026, the Colorado State Board of Accountancy (“the Board”) adopted revised rules implementing Senate Bill 26-076 (SB26-076), marking a major step toward expanding pathways to CPA certification.

Signed into law by Governor Jared Polis on May 4, 2026, following unanimous Senate approval and strong bipartisan support in the House, the legislation creates additional combinations of education and experience for aspiring CPAs. While SB26-076 establishes the new pathways, the Board’s rules define how they will work in practice, including specific education coursework requirements. 

The October 21 hearing marked the culmination of a two-month rulemaking process during which the Board gathered public and stakeholder feedback and refined the proposed rules in response. At the hearing, the Board formally adopted the rules, including revisions made during the session. While this is a significant milestone, a few procedural steps remain before the rules become final. 

Under Colorado’s Department of Regulatory Agencies (DORA) rulemaking process, the adopted rules must undergo review by the Attorney General before being filed with the Secretary of State and published in the Colorado Register. The agency has up to 180 days to complete the filing process. Barring any further delays, the rules are expected to take effect on January 1, 2027, aligning with the implementation timeline established by SB26-076.

Colorado’s Rulemaking Process

Inside the Hearing: COCPA’s Voice at the Table

Fifteen members of the public attended the October 21 hearing, where the Colorado State Board of Accountancy reviewed written stakeholder comments and heard additional testimony from virtual participants. Rather than simply voting on the rules as drafted, Board members actively considered feedback, discussed proposed changes, and refined the regulatory language in real time.

Among those providing testimony were Alicia Gelinas, CPA, President and CEO of the Colorado Society of CPAs (COCPA), and Lisa Kutcher, head of the Accounting Department at Colorado State University in Fort Collins. Kutcher also served on COCPA’s Licensure Task Force, which developed the recommendations submitted to the Board. Both emphasized the importance of ensuring that the rules are clear, consistent, and practical to implement for candidates and educators.

Throughout the hearing, the Board addressed several concerns raised by COCPA and incorporated refinements intended to improve clarity and consistency. The discussion demonstrated the value of stakeholder engagement in shaping the rules that will guide Colorado’s expanded CPA licensure pathways under SB26-076.

Overview of COCPA’s Rulemaking Recommendations

COCPA’s October 20 letter built on its September 9 stakeholder submission, several recommendations from which the Board had already incorporated. The remaining recommendations focused on technical and editorial refinements to improve clarity and consistency without introducing substantive changes that would require another round of public comment.

The recommendations addressed three key areas:

1. Clarifying Exam Eligibility for Combined Dual-Degree Programs: Clarifying that candidates enrolled in combined bachelor’s and master’s degree programs may sit for the CPA Exam before their bachelor’s degree is formally conferred, provided they have completed all bachelor’s-level degree requirements and the minimum required accounting and business coursework.
2. Aligning Examination and Certification Coursework Requirements: Applying consistent educational provisions and limitations across both sections on eligibility for examination and certification, including the three-hour auditing course, nine-hour single-subject credit cap, and three-hour internship credit limitation, while preserving pathway-specific credit-hour differences.
3. Streamlining Accounting Program and Concentration Definitions: Consolidating acceptable accounting and business subject areas into a single reference, eliminating duplicative language, and explicitly aligning the definition of the non-accounting degree with an accounting concentration established under SB26-076 with that of an approved accounting program.

These recommendations and others were intended to make the rules clearer and easier for candidates, educators, and employers to understand and apply. During the hearing, the Board considered COCPA’s feedback and adopted revisions addressing key areas.

For additional details, read COCPA’s full October 20 comment letter here.

Business Coursework Requirements: A Discussion That Continues

Not all public comments resulted in changes to the adopted rules. Some stakeholders questioned the 24-semester-hour general business coursework requirement and whether a master’s degree in accounting could be sufficient to satisfy it. In its letter, COCPA acknowledged these concerns while emphasizing that SB26-076 expanded overall educational pathways to CPA licensure but did not eliminate the foundational accounting and business knowledge expected of candidates. 

COCPA supported retaining the 24-hour requirement, reduced from Colorado’s previous 27-hour requirement and consistent with the Uniform Accountancy Act (UAA) Model Rules developed by the National Association for State Boards of Accountancy (NASBA). These model rules provide a framework for promoting consistency across states while allowing flexibility in individual state requirements. As CPA licensure pathways continue to evolve, state CPA societies have encouraged NASBA to consider updates to the model rules.

While COCPA recognizes the potential merit of specific graduate degree exemptions, differences among programs warrant further evaluation. An important consideration ensuring that candidates educated under Colorado’s requirements are adequately prepared should they pursue initial licensure in another state, particularly as many states continue to maintain a separate hours-based business coursework requirement. COCPA plans to continue researching how these requirements affect candidates and interstate mobility and share future recommendations with the Board.

What comes next

Following the Attorney General’s review and publication of the final rules, Colorado’s new CPA licensure requirements are expected to take effect on January 1, 2027. Candidates preparing to sit for the CPA Exam or apply for certification, along with the educators or employers who advise them, should review the final rules to understand how the updated education and experience requirements apply to their circumstances. COCPA remains committed to supporting a smooth transition and will provide additional guidance and resources to help candidates, educators, and employers navigate the new rules and pathways to licensure.