Regardless of where CPAs are employed, they should be able to use their title, in conjunction with their business activity, as long as they meet certain licensing criteria, meet continuing professional education (CPE) standards, and are subject to regulation by a state board of accountancy.
The concept of “CPA=CPA” was created in the Final Report of the AICPA/NASBA Joint Committee on Regulation of the Profession. In the report, the Joint Committee recommended that all CPAs, regardless of their particular field or place of employment, be subject to licensure and regulation by the state board of accountancy.
Provisions in the Uniform Accountancy Act (UAA) accomplish this concept by requiring all individuals who wish to use the CPA title to hold a valid license. Individuals may obtain a CPA license once they demonstrate they have met appropriate education, examination and experience requirements. The license must be renewed by demonstrating compliance with a CPE requirement.
Importance to CPAs
Court decisions have supported that duly licensed CPAs may use their "CPA" designation while working in non-CPA firms. As a result, the definitions of "holding out" and "practice of public accountancy" have been removed from the UAA. Now, under the framework of the UAA, regardless of where CPAs are employed or what they do, all licensed CPAs are subject to regulation by the state board.
As long as individuals hold a CPA license they are subject to the authority of the state board of accountancy, regardless of what they do for a living and regardless of whether they use their CPA title. All licensees must comply with the accountancy law and regulations.
To be consistent with the broad regulatory approach envisioned under this concept, the initial experience requirement in the UAA has changed. The “public accounting” experience requirement, contained in previous editions of the UAA, was restrictive and did not reflect today’s environment for CPA services. The UAA contains a broad experience requirement for initial licensure of one year of providing any type of professional service or advice involving the use of accounting, attest, management advisory, financial advisory, tax or consulting skills. As part of the application process for licensure, a licensed CPA must verify this experience. This experience (professional service or advice) can be gained through employment in government, industry, academia, or public practice.
Likewise, to reflect the equality of this new regulatory framework, all licensees as a provision for re-licensure must complete CPE.
As states have adopted the core provisions of the UAA, they are incorporating the concept of CPA=CPA by moving from a two-tier regulatory structure to a one-tier structure and requiring CPE for all licensees.