ARCCPA-NASBA Joint UAA Committee - RE: March 4, 2025 Exposure Draft to the Uniform Accountancy Act, Eighth Edition – January 2018

Sep 2, 2026

Uploaded by Asher

The Arkansas Society of CPAs (ARCPA) has reviewed the current exposure draft dated March 4, 2025, and appreciates the opportunity to respond to the amendments related to UAA Sections 5 and 23 regarding education requirements for the CPA Exam and education requirements for a certificate. The ARCPA, representing the premier professional home for CPAs and accounting professionals in Arkansas, with approximately 2,300 member CPAs and 6,000 licensed CPAs in the state, has engaged with this proactive regulatory advancement. Many states have passed legislation this year allowing multiple pathways to licensure, prompting Arkansas to update its statute to specify at least one year of experience for licensure and move substantial equivalency out of statute and over to Board Rule. ARCPA also supports the board's proposed rule revision to offer an additional pathway to a Baccalaureate degree with a concentration in accounting, plus two years of general work experience, with a proposed effective date of January 2026. This new pathway is believed to adequately prepare candidates for licensure without the undue burden of incorporating the additional time and cost associated with completing a fifth year of education. This decision to offer multiple pathways to licensure will aid in promoting consistency across all U.S. auditing jurisdictions. We believe that allowing candidates to begin sitting for the CPA Exam earlier will help with the declining pipeline. We have heard from many Arkansas students that they are electing to pursue other professional careers that do not require evidence of passing a difficult exam. Furthermore, regarding substantial equivalency and practice privilege, we believe that passage of the Exam should be the sole qualifying condition for determining substantial equivalency and interstate mobility. At least half of currently licensed CPAs in the U.S. were licensed under the original 120-hour/one year of experience requirement and had practice privileges across state lines for more than two decades. To suggest that state statutes and/or rules should now require one of the three education and experience pathways in addition to passing the Exam would cause undue confusion and complexity. We believe a licensed CPA from any state, as long as they have passed the Exam, should be able to practice accounting in any state with one approved license. We agree with the removal of the National Qualification Appraisal Service (NQAS) for determining substantial equivalency, as we believe that state boards of accountancy should have the authority to determine qualification to practice accounting in their respective states, rather than a national entity.

LanguageEnglish

CategoryExam

FormatPDF

Pages175

Reading Time7 h 21 min

AccessFree to download

Response to the Exposure Draft

1. Education Requirements for CPA Exam and Certificate

2. Substantial Equivalency and Practice Privilege

3. National Qualification Appraisal Service (NQAS)

FAQs

What is the main purpose of the letter?

The letter from the Arkansas Society of CPAs (ARCPA) provides comments and feedback on the proposed amendments to the Uniform Accountancy Act related to CPA licensure and education requirements.

What new pathway to licensure does ARCPA support?

ARCPA supports a proposed rule revision that offers a pathway to licensure requiring a Baccalaureate degree with an accounting concentration, plus two years of general work experience.

What is ARCPA's stance on substantial equivalency?

ARCPA believes that passing the CPA Exam should be the sole qualification for determining substantial equivalency and interstate mobility, rather than requiring additional education or experience pathways.

Sep 2, 2026

Uploaded by Asher