SB 522 proposes amendments to Section 901.259(a) of the Texas Occupations Code, which governs the issuance of Certified Public Accountant (CPA) certificates to individuals licensed in other states. The bill streamlines the licensure recognition process by eliminating prior reliance on verification from the National Association of State Boards of Accountancy (NASBA) for determining equivalency. Instead, the bill establishes three alternative pathways that allow the Texas State Board of Public Accountancy to issue a CPA certificate to an out-of-state applicant.
Under the new provisions, an individual may qualify for a Texas CPA certificate if they: (1) satisfy all Texas requirements for certification except for specific CPA exam grade thresholds; (2) met Texas licensure requirements as they existed at the time of licensure in their home state; or (3) have completed at least four years of post-exam public accountancy experience within the ten years preceding their application, provided that experience meets standards set by board rules.
The proposed changes enhance flexibility and accessibility for experienced CPAs from other states seeking to practice in Texas. By updating the statute to focus more on professional competency and less on bureaucratic credential evaluations, the legislation encourages workforce mobility and professional growth. These adjustments align with broader efforts to modernize occupational licensing processes in Texas and foster a business-friendly regulatory environment.
The differences between the originally filed version of SB 522 and its Committee Substitute represent a significant shift in the bill’s focus and regulatory philosophy. While both versions aim to ease licensure or practice requirements for out-of-state Certified Public Accountants (CPAs) in Texas, they take notably different approaches in doing so.
The originally filed bill seeks to amend Section 901.462 of the Occupations Code, primarily addressing practice privileges for CPAs whose principal place of business is outside of Texas. It outlines a dual-path eligibility system—either through a comparability determination of the other state’s licensure standards or through a detailed breakdown of educational and experience qualifications. Importantly, it allows the Texas State Board of Public Accountancy to optionally use NASBA's National Qualification Appraisal Service (NQAS) as a tool for determining equivalency. This version reflects a cautious, layered approach that continues to rely, at least in part, on external national standards while retaining board discretion.
By contrast, the Committee Substitute revises Section 901.259(a) and shifts the focus from practice privilege to the actual certification process in Texas. It discards reliance on NASBA entirely and replaces it with three new pathways for certification: meeting current requirements excluding exam grade criteria, meeting the requirements at the time of original licensure in another state, or demonstrating four years of qualifying public accountancy experience. This substitute version simplifies the framework, prioritizes flexibility, and aims to reduce regulatory overhead for experienced professionals seeking to work in Texas.
In essence, the Committee Substitute modernizes and localizes the CPA licensure process, stripping away dependency on national third-party evaluations and focusing instead on practical, Texas-determined qualifications. It signals a more autonomy-driven and applicant-friendly approach to regulatory reform compared to the originally filed bill.