A CPA is a license, not a certification. The word “certified” in Certified Public Accountant is misleading: the credential is issued by a state board of accountancy under state law, and only a licensed CPA can legally perform certain accounting services or use the title. A private certification, by contrast, is awarded by a professional organization and carries no legal authority over who works in the field.
What Makes the CPA a License
A license exists because a government agency controls it. State boards of accountancy grant CPA licenses, set the conditions for keeping them, and can revoke them. The Uniform Accountancy Act, a model law developed jointly by the American Institute of Certified Public Accountants and the National Association of State Boards of Accountancy, provides the framework state legislatures use when writing their own accountancy statutes.1AICPA & CIMA. What Is the Uniform Accountancy Act Each state board enforces those statutes, investigates complaints, and holds the power to strip the credential entirely.
Private certifications work differently. Organizations like the CFA Institute or the Institute of Management Accountants award credentials based on exam performance and continuing education, but they cannot stop you from working if you lose the designation. A state board of accountancy can. If your CPA license is revoked, performing attestation work or even calling yourself a CPA becomes illegal. That enforcement power is what separates a license from a certification.
A few jurisdictions historically used a two-tier structure that awarded a “certificate” after the exam and a separate “license” once experience requirements were met. Most states have moved to a single license issued after all requirements are satisfied. Whatever the local structure, you cannot practice public accounting without the license.
What the License Legally Lets You Do
Holding the license unlocks specific rights that unlicensed accountants and holders of private credentials do not have.
Under Treasury Department Circular 230, licensed CPAs have unlimited representation rights before the Internal Revenue Service.2Internal Revenue Service. Treasury Department Circular No. 230 You can represent any taxpayer on any matter before the IRS, including audits, appeals, and collection disputes. You can prepare and file tax documents, correspond with the IRS on a client’s behalf, and provide written tax advice.
This is a meaningful line. Someone with just a Preparer Tax Identification Number can prepare returns but cannot represent clients beyond basic interactions. Enrolled agents, who pass the IRS’s own exam, also have unlimited representation rights, but CPAs get those rights automatically through their state license.3Internal Revenue Service. Understanding Tax Return Preparer Credentials and Qualifications If the state license lapses or is suspended, those federal rights disappear with it.
The license also carries exclusive authority to sign audit reports and perform other attestation work. This is why the credential matters in law: certain services cannot legally be performed by anyone without it.
What Happens If You Use the Title Without One
Because the CPA is a license, using the title or performing restricted services without a valid one is a legal violation, not just an ethical one. State boards have enforcement tools that range from cease-and-desist letters to administrative fines, injunctions, and criminal prosecution. Penalties for a first offense of using a restricted title without authorization can start at $1,000 and climb well above $5,000 for repeated violations or for performing attestation services without a license.
Enforcement typically starts with a complaint. Clients, colleagues, or regulators can file one with the state board. The board investigates, contacts the person accused, and determines whether a violation occurred. Consequences range from a warning letter to referral for criminal prosecution. In many states, unauthorized practice of public accountancy is classified as a misdemeanor.
These rules apply equally to people who never held a license and to CPAs whose license lapsed. If your license expired last month and you sign an audit opinion today, you are practicing without a license. The board does not weigh the fact that you were licensed last year.
What It Takes to Earn the License
Every jurisdiction structures CPA licensure around four requirements: education, examination, experience, and ethics. The specifics vary by state, but the framework is consistent because the Uniform Accountancy Act sets the baseline most boards follow.
Education
Licensure requires 150 semester hours of college education, roughly 30 credit hours beyond a standard four-year bachelor’s degree. Most candidates earn the extra hours through a master’s program, a double major, or additional coursework. Boards typically require a concentration in accounting, though the exact number of accounting-specific credits differs by jurisdiction.4NASBA National Association of State Boards of Accountancy. Substantial Equivalency
Examination
Candidates must pass the Uniform CPA Examination, which requires a minimum score of 75 on each section.5AICPA & CIMA. Learn More About CPA Exam Scoring and Pass Rates Under the CPA Evolution model that took effect in 2024, candidates sit for three core sections and one discipline section of their choice.6AICPA & CIMA. Everything You Need to Know About the CPA Exam
Experience
Most states require one to two years of supervised professional experience, commonly around 2,000 hours, though some jurisdictions set the bar at 1,750. The work must involve accounting, tax, advisory, or attestation services and must be verified by a CPA who holds an active license. Experience does not have to come from a public accounting firm; work in government, private industry, or academia counts in most jurisdictions.
Ethics
Many states require a separate ethics exam covering the AICPA Code of Professional Conduct before issuing a license. Some jurisdictions accept the AICPA’s own ethics course and exam; others use their own. Passing scores tend to be higher than the CPA exam itself, often 90 percent.
Keeping the License Active
Earning the license is a one-time process. Keeping it is not. Every jurisdiction requires continuing professional education as a condition of renewal. The Uniform Accountancy Act model rules set the standard at 80 hours of CPE over a two-year reporting period, with a portion dedicated to ethics coursework. Some states use annual or three-year renewal cycles instead.7NASBA National Association of State Boards of Accountancy. Licensure Deadlines vs CPE Deadlines – Whats the Difference
CPE hours must come from approved providers, and you self-report them through the board’s online portal. Boards conduct random audits to verify compliance. If audited, you need to produce completion certificates showing your name, the course title, the field of study, dates attended, hours awarded, and the program sponsor. Keep those records for at least five years. Without documentation, the board will not credit the hours.
Renewal fees typically range from $50 to $500. Missing a deadline triggers late fees, and many boards offer a 30-day grace period with a surcharge. Past that window, the license lapses. Reinstatement usually costs more and requires proof that all required CPE was completed before the board will reactivate the license. Fines for CPE deficiencies can range from $50 to several thousand dollars.
If you stop practicing but want to preserve the credential, most states allow inactive status. An inactive CPA cannot perform attestation work, sign audit reports, or hold themselves out as a practicing CPA, but the license stays on file and CPE requirements pause. Returning to active status later means catching up on CPE, usually a reduced number of hours completed in the year before reactivation, plus paying the standard renewal fee.