Accountancy Practice Amendment Act of 2025

MURIEL BOWSER
MAYOR

November 20, 2025

The Honorable Phil Mendelson
Chairman
Council of the District of Columbia
John A. Wilson Building
1350 Pennsylvania Avenue, NW, Suite 504
Washington, DC 20004

Dear Chairman Mendelson:

Enclosed for consideration and adoption by the Council of the District of Columbia is the
Accountancy Practice Amendment Act of 2025. In 2024, the National Association of State
Boards of Accountancy (NASBA) proposed changes to the Uniform Accountancy Act (UAA).
NASBA’s proposed rule changes focused on licensure and mobility. Specifically, NASBA
proposed adopting a third pathway of licensure, which would allow one to obtain a CPA license
if they have a bachelor’s degree, two years of work experience, and pass the examination.
Presently, one must have a baccalaureate degree, with or without an accountancy concentration,
plus 30 additional credit hours, which is usually a Master’s degree, one year of supervised work
experience, and passing the CPA examination. The new pathway will allow one who has
obtained a baccalaureate degree, with or without an accountancy concentration, to obtain a CPA
license by completing two years of supervised work experience and passing the CPA
examination. One year of work experience can be satisfied by completing an additional 30 credit
hours.

This change would allow a prospective accountant to begin working earlier while they prepare to
take the CPA examination. One of the barriers to licensure has been education requirement. The
cost of education, particularly obtaining a master’s degree, has been a deterrent for some who
may otherwise want to become a licensed CPA. Further, there has been a decline in licensed
CPAs across the country, including in the District. This legislation would address this. The
newly amended mobility provisions would ensure that accountants under this licensure path that
are licensed in one state may practice in another.

Since NASBA proposed these changes, 29 states, including Maryland and Virginia, have
amended the CPA licensure requirements consistent with these proposals. Specifically, during
the 2025 legislative session, Virginia adopted the alternative pathway to licensure and mobility,
effective January 1, 2026, and Maryland adopted the its mobility requirements during the 2025
General Assembly Session. Given the District’s proximity to these two jurisdictions, and the
number of D.C.-licensed CPAs that practice in Virginia and Maryland, it is imperative to ensure
that the District does not fall behind its neighboring jurisdictions in coming in line with modern
standards.
I encourage the Council to adopt the Accountancy Practice Amendment Act of 2025. If you
have any questions regarding this legislation, please contact Tiffany Crowe, Director,
Department of Licensing and Consumer Protection, at tiffany.crowe@dc.gov.
Sincerely,
Muriel Bowser

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~?.~
at the request of the Mayor
A BILL
IN THE COUNCIL DISTRICT OF COLUMBIA
To amend Chapter 28 of Title 4 7 of the District of Columbia Official Code to revise the
eligibility requirements for accountancy licensure by authorizing a holder of a
baccalaureate degree with two years of experience and who has passed the an
examination in accounting and auditing to obtain a license, to allow the Mayor the add
additional licensure requirements by rulemaking, and to amend the mobility requirements
for those who are licensed in another jurisdiction and want to practice in the District.
BE IT ENACTED BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, That this
act may be cited as the "Accountancy Practice Amendment Act of 2025".
Sec. 2. Chapter 28 of Title 47 of D.C. Official Code is amended as follows:
(a) D.C. Official Code§ 47-2853.42 is amended to read as follows:
"§ 47-2853.42. Eligibility requirements.
"(a) An applicant for licensure as a certified public accountant shall establish to the
satisfaction of the Board that the applicant:
"(l) Has passed an examination in accounting and auditing and such related
subjects as the Board shall detem1ine to be appropriate;
"(2)(A) Holds a baccalaureate or post-baccalaureate degree with a concentration
in accounting conferred by a college or university acceptable to the Board or holds a degree the
Board determines to be substantially equivalent thereto; or
“(B) Holds a baccalaureate degree conferred by a college or university 35
acceptable to the Board supplemented with the equivalent of an accounting concentration, which 36
may include related courses in other areas of business administration; 37
“(3) Has completed the following years of relevant experience: 38
“(A) Two years for an applicant that holds a baccalaureate degree 39
described in paragraph (2)(A) or (B) of this subsection, of which one year may be substituted by 40
having completed an additional 30 semester credit hours above the minimum hours required for a 41
baccalaureate degree; or 42
“(B) One year for an applicant that holds a post-baccalaureate degree 43
described in paragraph (2)(A) of this subsection; and 44
“(4) Meets any other requirements established by rule. 45
“(b) For the purposes of subsection (a)(3) of this section: 46
“(1) “Relevant experience” means providing service or advice representing the 47
skills needed at the time of licensure to serve the public as a certified public accountant. 48
“(2) Relevant experience includes providing any type of business services or 49
advice using accounting, attest, compilation, management advisory, financial advisory, tax, or 50
consulting skills, to the extent such experience has been verified by a person licensed as a 51
certified public accountant. 52
“(3) Whether the experience of an applicant constitutes relevant experience shall 53
be determined by the Board. 54
“(c) The Mayor, pursuant to Title I of the District of Columbia Administrative Procedure 55
Act, approved October 21, 1968 (82 Stat. 1204; D.C. Official Code § 2-501 et seq.), may 56
establish additional licensure requirements by rule to ensure that the applicant has the proper 57
training, experience, and qualifications to practice as a certified public accountant.”. 58
(b) D.C. Official Code § 47-2853.49 is amended as follows: 59
(1) The section heading is amended to read as follows: 60
“47-2853.49. Practice privilege.”. 61
(2) Subsections (a) and (b) are amended to read as follows: 62
“(a) An individual whose principal place of business is not in the District shall have all 63
the privileges of a licensee of the District without the need to obtain a license under § 47-64
2853.42; provided that, the individual: 65
“(1) Holds a valid, unrestricted license as a CPA in good standing issued by 66
another state or territory of the United States; and 67
“(2) At the time of initial licensure in the other state or territory, the individual 68
was required to show evidence of having: 69
(A) Passed the Uniform CPA Examination or another certified public 70
accountant examination approved by the Board; 71
“(B) Satisfied education requirements equivalent to those set forth in § 47-72
2853.42(a)(2); and 73
“(C) Satisfied experience requirements equivalent to those set forth in § 74
47-2853.42(a)(3); ”. 75
“(b) An individual whose principal place of business is not in the District, is licensed as a 76
CPA in good standing in another state or territory of the United States, and had practice 77
privileges in the District under the version of this section that was in effect immediately prior to 78
the effective date of the Accountancy Practice Amendment Act of 2025 shall continue to have all 79
privileges of a licensee in the District without the need to obtain a license under § 47-2853.42 80
regardless of whether the individual meets the requirements of this section on the effective date 81
of the Accountancy Practice Amendment Act of 2025.”. 82
(3) Subsection (d) is amended by striking the phrase “shall simultaneously 83
consent, as a condition of the grant of the privilege” and inserting the phrase “shall be deemed to 84
have simultaneously consented, as a condition of the exercise of the privilege” in its place. 85
Sec. 3. Fiscal impact statement. 86
The Council adopts the fiscal impact statement of the Chief Financial Officer as the fiscal 87
impact statement required by section 4a of the General Legislative Procedures Act of 1975, 88
approved October 16, 2006 (120 Stat. 2038; D.C. Official Code § 1-301.47a). 89
Sec. 4. Effective date. 90
This act shall take effect following approval by the Mayor (or in the event of veto by the 91
Mayor, action by the Council to override the veto), 30-day period of congressional review as 92
provided in section 602(c)(1) of District of Columbia Home Rule Act, approved by December 93
24, 1973 (87 Stat. 813; D.C. Official Code § 1-206.02(c)(1)), and publication in the District of 94
Columbia Register. 95
Government of the District of Columbia
Office of the Chief Financial Officer

Glen Lee
Chief Financial Officer

1350 Pennsylvania Avenue, NW, Suite 203, Washington, DC 20004 (202)727 -2476
www.cfo.dc.gov
MEMORANDUM

TO: The Honorable Phil Mendelson
Chairman, Council of the District of Columbia

FROM: Glen Lee
Chief Financial Officer

DATE: October 10, 2025

SUBJECT: Fiscal Impact Statement – Accountancy Practice Amendment Act of
2025

REFERENCE: Draft Bill as provided to the Office of Revenue Analysis on October 1,
2025

Conclusion

Funds are sufficient in the fiscal year 2026 through fiscal year 2029 budget and financial plan to
implement the bill. to implement the bill. The Department of Licensing and Consumer Protection
(DLCP) can implement the bill within current resources.

Background

The Board of Accountancy (Board) is a division of DLCP that regulates the licenses of professional
accountants and upholds the District accountancy license law and District license law.1 The Mayor
establishes the fee schedules for all services related to the regulation of occupations and professions.2

To be eligible for licensure as a certified public accountant (CPA) under current law 3, an applicant
must establish that they have passed an examination4, hold a baccalaureate degree in the equivalent

1 Government of the District of Columbia. (2025, October 5). Board of Accountancy. Retrieved from District of
Columbia Department of Licensing and Consumer Protection: https://dlcp.dc.gov/page/board -accountancy
2 D.C. Official Code § 47–2853.10(d).
3 D.C. Official Code § 47-2853.42.
4 The examination must be in accounting and auditing and such related subjects as the Board of Accountancy
determines to be substantially equivalent (D.C. Official Code § 47-2853.42(3)).
The Honorable Phil Mendelson
FIS: “Accountancy Practice Amendment Act of 2025”, Draft Bill as provided to the Office of Revenue Analysis
on October 1, 2025

Page 2 of 2

of an accounting concentration, possess 150 semester hours of college education, and meet any other
requirements established by rule. The bill revises the eligibility requirements for accountancy
licensure by requiring between one and two years of experience depending on degree level and
semester hours 5. The Mayor has rulemaking authority to establish additional licensure
requirements.

The bill also amends the reciprocity requirements for those who are licensed in another jurisdiction
and want to practice in the District. Current law6 provides for a CPA licensed in another jurisdiction
to practice in the District if their education, examination, and experience meet the substantial
equivalency requirements defined by the Board, based on the standards of the Uniform Accountancy
Act (UAA) 7. If the principal place of business is outside the District, the individual is presumed
substantially equivalent in their qualifications and is not required to obtain a license from the District,
provided they hold a valid unrestricted license as a CPA from another state that is NASBA7 National
Qualification Appraisal Service verified8. The bill repeals Board determination on substantial
equivalency6 and amends the code to allow an individual whose principal place of business is outside
the District to practice in the District without having to obtain licensure provided the individual:
holds a license in good standing from another United States jurisdiction9, has passed a Board
approved CPA examination, and as of December 31, 2024, had practice privileges in the District.

Financial Plan Impact

Funds are sufficient in the fiscal year 2026 through fiscal year 2029 budget and financial plan to
implement the bill. The DLCP can implement the bill within current resources. The DLCP does not
anticipate a material change to revenues generated from accountancy licensure issuance.10

5 After January 1, 2026, two years of experience will be required for those applicants that hold a
baccalaureate degree, of which one year may be substituted by completing an additional 30 semester hours;
or one year for those applicants that possess a master’s degree with an accounting concentration or
equivalent.
6 D.C. Official Code § 47–2853.49(a).
7 National Association of State Boards of Accountancy (NASBA). (2007, July 7). Uniform Accountancy Act Fifth
Edition. Retrieved from https://www.nasba.org/files/2011/04/UAA_Fifth_Edition -Jul07.pdf
8 That is, verified to be in substantial equivalence with American Institute of Certified Public Accountants
(AICPA)/NASBA Uniform Accountancy CPA licensure requirements. If the individual holds a valid
unrestricted license as a CPA from a non-verified state, they must obtain verification from the NASBA
National Qualification Appraisal Service that their CPA qualifications are substantially equivalent to the CPA
licensure requirements of the UAA.
9 That is, another state or US territory.
10 Fees collected for accountancy licenses are deposited in the Occupations and Professions Licensure Special
Account pursuant to D.C. Code § 47–2853.11.
2

GOVERNMENT OF THE DISTRICT OF COLUMBIA
OFFICE OF THE ATTORNEY GENERAL

BRIAN L. SCHWALB PRIVILEGED AND CONFIDENTIAL
ATTORNEY GENERAL ATTORNEY-CLIENT COMMUNICATION

LEGAL COUNSEL DIVISION

MEMORANDUM

TO: Tomás Talamante
Director
Office of Policy and Legislative Affairs

FROM: Adele El-Khouri
Deputy Attorney General
Legal Counsel Division

DATE: September 29, 2025

SUBJECT: Legal Sufficiency Review of Draft Legislation, the “Accountancy Practice
Amendment Act of 2025”
(AE-25-55)
_____________________________________________________________________________________

This is to Certify that the Office of the Attorney General has reviewed the
above-referenced legislation and found it to be legally sufficient. If you have any questions in this
regard, please do not hesitate to call me at (202) 262-6402.

_________________________________
Adele El-Khouri