The American Institute of CPAs and the National Association of State Boards of Accountancy have proposed changes in the Uniform Accountancy Act model legislation used by states to provide an additional path to CPA licensure, while preserving CPA mobility across the states.
The AICPA and NASBA asked the joint UAA committee to draft proposed model law language in two main areas: A bachelor’s degree plus two years of experience as a pathway to licensure that incorporates a broad role for experience, to be determined at the state level; and individual-based practice privilege that incorporates a CPA’s ability to practice across state lines.
The recommended changes come as state CPA societies and lawmakers in various states have been looking at ways to attract more young people to the accounting profession, providing more flexibility in attaining a CPA license without jeopardizing the ability of CPAs to practice across state lines. Last month, Ohio’s governor signed into law a bill backed by the Ohio Society of CPAs that provides alternatives to the traditional 150-credit hour requirement.
The comment letters received in response to two recent AICPA and NASBA exposure drafts, along with early 2025 state legislative activity such as Ohio’s indicate a growing preference for an individual practice privilege and a bachelor’s degree plus two years of experience path. Feedback also supported a more in-depth study of competencies as they relate to the experience requirement.
“The accounting profession has seen a remarkable convergence in recent weeks of stakeholders around flexibility that creates greater access for those who are interested in pursuing a career in accounting,” said Susan Coffey, CEO of public accounting at the Association of International Certified Professional Accountants. “A bachelor’s plus two years of experience path, in which states define the needed skills and competencies, is responsive to the market and protects the public.”
The proposal would maintain the existing two pathways of a master’s degree plus one year of experience, as well as a bachelor’s degree plus 30 credits plus one year of experience.
The UAA is jointly published by AICPA and NASBA and gives state legislatures and boards of accountancy a national model they can either adopt as is or adapt to meet the needs of each jurisdiction. The proposed UAA language will be open for public comment for 60 days.
“We look forward to the expertise and perspectives the 55 U.S. licensing jurisdictions will share during this next comment period,” said NASBA president and CEO Daniel Dustin in a statement. “We believe that any new proposal, and the feedback received from all stakeholders, will not only result in a thriving profession but also one that, because it keeps its eye on protecting the public, will allow that public to continue to trust in a CPA’s work.”
The AICPA and NASBA opened a call for comments last September asking about a proposed initiative to help CPA candidates meet initial licensure requirements by exhibiting their competency in specific professional and technical areas. Later that month, they also issued a set of corresponding UAA model legislative amendments for discussion. Comments on the proposals can be accessed through the NASBA and AICPA websites. The feedback indicated support for the concept of competencies, but not as proposed. Based on the volume and nature of responses, the AICPA and NASBA agreed to table the framework for intended purposes.
“Through continued collaboration and alignment, we’ll be able to achieve this shared goal of growing pathways into the profession, while protecting the public,” said Carla McCall, who serves as AICPA chair and co-chair of the Association of International Certified Professional Accountants. “This is an important and exciting step for our profession. We are ready to get this done.”
“The input and feedback from the members of the Boards of Accountancy and key stakeholders in the accounting profession is crucial to the UAA process,” said NASBA chair Maria Caldwell in a statement. “We appreciate the continued collaboration and expertise of the members of the joint UAA Committee.”
The feedback received on last September’s proposals indicated support for the concept of competencies, but not as proposed. Based on the volume and nature of responses, the AICPA and NASBA agreed to table the framework for intended purposes.
“As such, we are exploring plans for a longer-term, data-driven approach working with stakeholders to understand how competencies can help shape the future of our profession,” Coffey stated. “This aligns with recommendations made in 2024 by the National Pipeline Advisory Group and reinforces the profession’s longstanding commitment to competence as a core principle already in our profession’s Code of Professional Conduct and in the UAA.”
The AICPA and NASBA plan to work to redefine the UAA processes for greater inclusivity and transparency, as well as devote more resources to helping CPAs with navigating practice mobility as states enact legislation.
The Internal Revenue Service is reportedly planning layoffs of thousands of first-year probationary employees in the midst of tax season, perhaps as soon as this week.
The layoffs are set to occur despite assurances that the IRS would wait until May 15, a month after the end of tax season, before it would accept voluntary buyout offers under the Trump administration’s “deferred resignation” program. The administration instead moved to end that program last week soon after a federal judge allowed it to proceed. The buyout offer was accepted by approximately 75,000 federal employees.
The IRS and the National Treasury Employees Union did not immediately respond to requests for comment, but multiple news outlets, including the Associated Press, the New York Times, the Washington Post, NBC News and Fox News have reported on the plans. The cuts come after a team from the Elon Musk-led Department of Government Efficiency reportedly met with top IRS officials and sought access to sensitive taxpayer information that is normally closely guarded by IRS employees.
The American Institute of CPAs released a statement Sunday stressing the need for the IRS to have the ability to meet the needs of taxpayers and tax preparers during this filing season:
“For many years, one of the top priorities at the AICPA has been to promote efforts that ensure the IRS has the appropriate resources to meet the needs of taxpayers and preparers,” said the AICPA. “Our goal is to support taxpayers and our members during times of uncertainty and to provide guidance to help navigate any changes that may affect critical, time-sensitive interactions with the IRS. Many are concerned with potential challenges that could arise from recent changes throughout government. While there is a lot of speculation and many unknowns, the AICPA is actively monitoring the situation and engaging with IRS leadership and other key stakeholders to understand and mitigate the impact of these changes on IRS services. IRS service levels and modernization efforts have seen progress since the COVID-19 pandemic and we are committed to seeing those efforts continue. Americans deserve a fully functioning agency that can be respected by taxpayers and their preparers, thereby allowing them to comply with their tax obligations.”
The move to fire the probationary employees at the IRS comes as the Trump administration and DOGE have begun widespread layoffs at other departments of the federal government, not only of first-year employees, but of longer-serving employees who had earned civil service protections, along with effective shutdowns of agencies such as the U.S. Agency for International Development and the Consumer Financial Protection Bureau. That has prompted lawsuits and protests in Washington, D.C., and other cities across the country, but the layoffs have been paused at the CFPB for now by a federal judge. The same could happen with the IRS.
Expect plenty of changes in the world of tax under the new administration.
On Inauguration Day, President Donald Trump signed an executive order calling for a longer hiring freeze at the Internal Revenue Service than he was imposing on other federal agencies, as well as another executive order rejecting U.S. participation in the Organization for Economic Cooperation and Development’s two-pillar global tax framework. He also called for sending armed IRS agents to patrol the Mexican border, which the Department of Homeland Security later requested of the Treasury Department.
Republicans in Congress are currently negotiating the contours of an extension of Trump’s signature tax legislation, the Tax Cuts and Jobs Act of 2017, along with his campaign promises of exempting certain kinds of income, such as tips, Social Security income and overtime, from taxes.
Mark Everson, a former IRS commissioner who is currently vice chairman of Alliant, a tax consulting firm in Washington, D.C., believes the administration under Treasury Secretary Scott Bessent will focus on the international front with tariffs and sanctions.
“It will be relatively more aggressive in the international arena,” said Everson. However, he believes the OECD tax deal would only be implemented through an act of Congress in the aftermath of Trump’s executive order.
(For insights on the new administration’s impact on other areas of regulation, like the PCAOB, see our feature article.)
He also expects to see changes at the IRS, with less emphasis on enforcement and diversity, equity and inclusion programs. “Consistent with the move against DEI, my guess would be a return to enforcement without scrutiny of results by racial grouping,” said Everson. “There’s a lot of discussion of the impact disproportionately on minorities through the Earned Income Tax Credit in terms of audit rates. I don’t think that will be considered in this approach going forward, given what they’ve already done with the abolition of the DEI offices, including, as I understand it, at the service.”
However, he expects to see continuing improvements in taxpayer service. “I do think that there will be common ground in terms of emphasis on service improvements,” said Everson. “I’m not suggesting that everything at the IRS is going to stop. Hardly. The Republicans feel very strongly about the need for good service, and I think that will be a focus of the administration once, presumably, Commissioner [Billy] Long is in office. I think there will be continuation and a great deal of focus on privacy versus efficiency. They’ll want to make the improvements on the system side, which are already underway, but I do think there will be a great deal of focus on privacy.”
Hiring freeze
The hiring freeze at the IRS could be a concern, however.
“Will they be able to maintain adequate personnel? Time will tell on that, but I think we’ll know fairly quickly,” said Everson. “The filing season has already started, and I think that the impact of departures on the workforce will be felt over time. I’m not overly concerned about the filing season, per se. Over a period of time, if people are leaving government — and the IRS does have a very high component of people who have been working from home — because that is no longer allowed, what will the impact be there? That’s very much in the mix, but it will take time to feel the effects of that.”
He expects to see more of a focus at the IRS on process in terms of enforcement activities. Trump’s proposal to create an “External Revenue Service” to collect tariffs and duties could also introduce complications, since many of those functions are already performed at the Department of Homeland Security rather than the Treasury Department.
Former Representative Billy Long, a Republican from Missouri, speaking at a Donald Trump campaign event
Al Drago/Bloomberg
After the election, Trump named former Rep. Billy Long, R-Missouri, to be the next IRS commissioner, even though IRS Commissioner Danny Werfel’s term was scheduled to run until November 2027. That prompted Werfel to announce his last day would be on Jan. 20, coinciding with Inauguration Day. When he was in Congress, Long had sponsored a bill to abolish the IRS and replace it with a consumption-based tax known as the Fair Tax. In January, a group of 12 Republican lawmakers revived the bill as the Fair Tax Act of 2025.
The Trump administration and Republicans in Congress have been moving to claw back at least half of the $80 billion in extra funding under the Inflation Reduction Act from the IRS’s enforcement efforts, which had been targeting large partnerships and corporations, as well as high-wealth individuals, for increased audits. That could affect the reliance of the agency on doing centralized partnership audits, which were allowed under the Bipartisan Budget Act of 2015, but have only recently begun being used.
“Without the IRA funding — and as it stands today, there’s no funding coming from any additional sources — it is certainly less likely that the IRS will be able to conduct effective audits of partnerships,” said Colin Walsh, principal and practice leader of tax advocacy and controversy services at Top 10 Firm Baker Tilly. “Something could change tomorrow, and Billy Long could become commissioner and figure out a different way to finance it. Billy Long will have his own ideas, and we’re all curious to see how he’d like to build the IRS. There’s a big push to get federal workers back into the office. What impacts might that have? Maybe the theory could be that people working in an office are going to be more effective and more efficient than people working remotely. I don’t think at this stage we can even predict, if Billy Long becomes the commissioner, what that will look like, but we can say that it is going to be different. I think comfortably, we could say it’s going to be different than what it would have been like if the IRS had $80 billion and Danny Werfel, versus $40 billion and Billy Long. It is different objectively.”
“It doesn’t mean that it will necessarily be less stringent,” he noted. “We just don’t know, whereas six months ago, we all had a pretty good idea of where this was headed, because the IRS was explicit in saying what they were going to do, creating a partnership audit task force, auditing 80 of the largest partnerships, and in practice, we were seeing that last year.”
The IRS and the Treasury may also cut back on labeling tax transactions such as micro-captive insurance as “transactions of interest.”
“The IRS lost all those cases on making things transactions of interest or reportable transactions by notice,” said Bill Smith, managing director of the national tax office at Top 25 Firm CBIZ Advisors. “They now have to go through the regulatory process, with proposed regulations, a notice and comment period, all of that. Having nothing to do with the change of administration, they suffered a pretty serious setback there. They suffered a setback with the elimination of Chevron deference. It’s all taxpayer favorable, but is it good, sound policy? The IRS collects something like 97% of the revenue for the United States. I don’t know if Elon Musk is going to be able to cut that much out. If you’re going to eliminate a lot of the income, you’d better start eliminating the expenses too.”
Virginia, Pennsylvania and Minnesota made headway this week in adding alternative paths to CPA licensure.
The Virginia House and Senate passed legislation Monday, backed by the Virginia Society of CPAs, that creates an additional pathway to licensure and ensures practice mobility for out-of-state CPAs, effective Jan. 1, 2026. This makes it the second state, behind Ohio, to create a new CPA pathway.
HB 2042 and SB 1042 allow CPA candidates to achieve licensure with a baccalaureate degree with the required accounting coursework, two years of experience and passing the CPA exam. Candidates can still follow the older pathway, which entails 150 hours of education, one year of experience and passing the exam, but “the new path allows accountants to opt for more real-world experience rather than take an additional 30 hours of education,” according to a news release.
“Increasing the options accountants have to become licensed has been a major focus of the VSCPA and the profession nationwide,” VSCPA president and CEO Stephanie Peters said in a statement. “With declining college enrollments and new majors like data analytics, the competition to attract students to the accounting profession is strong. Corporations can’t run without finance teams, and businesses rely on their CPAs for valuable tax planning and strategic advice. It’s crucial we develop new ways to get accountants licensed as CPAs to become the trusted business advisors that help keep our economy running.”
The VSCPA worked with Del. Holly Seibold, D-Fairfax, and Sen. Adam Ebbin, D-Fairfax, with support from VSCPA member and Del. Joe McNamara, CPA, R-Roanoke. Both bills passed the full General Assembly unanimously. The VSCPA does not currently see any barriers to Gov. Glenn Youngkin singing the legislation.
Virginia State Capitol
Martin Kraft
Pennsylvania and Minnesota
Pennsylvania introduced a Senate bill to add an extra pathway to CPA licensure, allowing CPA candidates to achieve licensure with 120 college credits, two years of relevant work experience verified by a Pennsylvania CPA and passing the CPA exam. The existing pathway requiring 150 credits is still available for candidates.
“At a time when the accounting profession faces a variety of pipeline challenges, it is crucial to create innovative pathways that meet the needs of today’s workforce while safeguarding the public trust and high standards that define the CPA designation,” PICPA CEO Jennifer Cryder said in a statement.
“We believe these updates are critical to the future of the accounting profession,” she added. “By working together with our stakeholders, we can modernize licensure laws without compromising the core principles that define the CPA profession.”
The initial memo introducing the bill was led by Sen. Scott Hutchinson, R-Venango, and Sen. Nick Pisciottano, CPA-inactive, D-Allegheny. A companion bill is set to be introduced in the state House by Rep. Ben Sanchez, D-Montgomery, and Rep. Keith Greiner, CPA, R-Lancaster.
Meanwhile, Minnesota introduced a Senate bill to add two more pathways to licensure, which would allow CPA candidates to achieve licensure with a bachelor’s degree along with two years of general work experience and passing the CPA exam, or a master’s degree with one year of experience and passing the exam.
The legislation also ensures automatic practice mobility and changes regulations to make the Minnesota State Board of Accountancy the entity determining substantial equivalency, not NASBA’s National Quality Appraisal Service.
A companion bill in the Minnesota House is expected to be introduced later this week.