In March 2025, the American Institute of CPAs (AICPA) and National Association of State Boards of Accountancy (NASBA) exposed proposed changes to the profession’s model law. At the end of the comment period (May 3, 2025) a total of 209 stakeholders submitted comments.
The UAA changes will:
Enable states to adopt a third licensure pathway (earn a bachelor’s degree, complete two years of professional experience and pass the CPA Examination)
Shift to an “individual-based” mobility model, which allows CPAs to practice in other states with just one license
Add safe harbor language to ensure CPAs who meet existing licensure requirements preserve practice privileges
Of the stakeholders who submitted comments, 64% approve of the updates, and 13% approve of the updates with changes, such as clarification on language or requirements. Overall, the profession supports adopting a third pathway to licensure and more uniform approach to interstate practice.
This document includes all submitted comments and a summary. The names of responding individuals and organizations are listed, unless the respondent specifically requested that identifying information be redacted.