SB 522

Overall Vote Recommendation
Yes
Principle Criteria
positive
Free Enterprise
neutral
Property Rights
positive
Personal Responsibility
positive
Limited Government
positive
Individual Liberty
Digest

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.

Author (1)
Charles Perry
Co-Author (1)
Paul Bettencourt
Sponsor (1)
Angie Chen Button
Co-Sponsor (1)
Angelia Orr
Fiscal Notes

According to the Legislative Budget Board (LBB), the bill is not expected to have a significant fiscal impact on the state. This assessment is based on the fact that the Texas State Board of Public Accountancy, the agency responsible for implementing the provisions of the bill, operates as a self-directed, semi-independent agency. As such, it funds its own operations and is prohibited from incurring costs to the state's General Revenue Fund, meaning its regulatory changes do not affect the state's budgeting process.

Moreover, the bill does not carry significant fiscal implications for local governments. Because the subject matter—out-of-state CPA licensure and certification—falls entirely under the jurisdiction of a state-level agency and does not mandate new local programs or enforcement mechanisms, local units of government are not expected to face any new administrative or compliance costs.

Overall, the bill allows for a more streamlined and flexible certification process without adding financial burdens to either state or local entities. The neutral fiscal impact enhances its appeal, particularly among policymakers concerned with cost-efficient regulatory reform.

Vote Recommendation Notes

Texas Policy Research recommends that lawmakers vote YES on SB 522 for its effective balance of professional standards with reduced regulatory burdens. At its core, the bill is designed to modernize and simplify the process by which Certified Public Accountants (CPAs) licensed in other states may obtain certification or practice rights in Texas. It reflects a clear commitment to streamlining occupational licensing—a concern for many who are wary of expanding regulatory gatekeeping.

Importantly, this bill does not increase occupational regulation. Instead, it removes cumbersome and sometimes costly requirements for third-party verification through the National Association of State Boards of Accountancy (NASBA). Previously, out-of-state CPAs often had to secure validation that their state’s standards were “comparable” to Texas’s, which added layers of delay and uncertainty. SB 522 eliminates this dependency and replaces it with more direct, transparent pathways to licensure—such as meeting past Texas standards or demonstrating sufficient professional experience.

This deregulatory shift is crucial for maintaining workforce mobility and protecting against regulatory overreach, especially in a field like accounting, where core competencies are already objectively tested via standardized exams and credentialed experience. The bill enhances the role of the Texas State Board of Public Accountancy without granting it new enforcement powers or increasing compliance obligations. It promotes accountability and professional rigor while easing unnecessary restrictions on qualified applicants.

Given these benefits—particularly its deregulation of the CPA credentialing process, fiscal neutrality, and alignment with free-market principles—SB 522 is a model example of reform that supports individual liberty, personal responsibility, and limited government. For those concerned about the unchecked growth of occupational licensing, this bill represents progress in the right direction.

  • Individual Liberty: The bill empowers out-of-state Certified Public Accountants (CPAs) by giving them more direct and flexible pathways to certification in Texas. It removes arbitrary hurdles—such as dependency on national verification services—that previously restricted qualified individuals from working in Texas. By allowing experienced professionals to be judged on their credentials and work history, it affirms the right of individuals to pursue their chosen professions without unnecessary governmental interference.
  • Personal Responsibility: The bill maintains high standards for competency by requiring CPA exam passage, specific educational benchmarks, and verifiable professional experience. This ensures that individuals are still held accountable for meeting professional expectations while eliminating needlessly duplicative or procedural barriers. In doing so, the bill rewards those who have taken responsibility for their careers and professional development.
  • Free Enterprise: By reducing barriers for skilled professionals to enter the Texas workforce, the bill supports a more competitive and mobile labor market. Businesses—especially in finance, auditing, and consulting—benefit from an expanded talent pool. The streamlined process encourages economic participation and innovation without compromising quality, which is a direct reinforcement of free enterprise values.
  • Private Property Rights: The bill does not directly affect property rights. However, by enabling more professionals to legally operate and offer services, it does uphold the broader economic freedom that underpins market participation and the right to contract.
  • Limited Government: The bill trims back an overly bureaucratic process by eliminating reliance on national gatekeepers and restoring decision-making authority to the Texas State Board of Public Accountancy. The bill simplifies regulation, avoids granting new enforcement powers, and respects the principle that the government should not impose more restrictions than necessary to protect the public.
Related Legislation
View Bill Text and Status