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Mandatory Continuing Education Questions & Answers for Public Accountancy

Introduction – The Requirement

Continuing education requirements are in place in several professions to support continuing professional competency and ensure the highest quality professional services for the public. The continuing education requirements for the profession of Public Accountancy are covered in Section 7409 of the New York State Education Law and Section 70.9 of the Regulations of the Commissioner of Education. This information is designed to respond to frequently asked questions about the CPE requirements for NYS licensed Certified Public Accountants (CPAs) and Public Accountants (PAs). It is not a substitute for reading the provisions of the applicable laws, rules and regulations.

General Information
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Licensed CPAs and PAs, performing any accounting, tax, financial or management advisory work in New York State, including work performed in private industry, government agencies, public accounting firms, not-for-profits, or an academia employer, are required to meet the continuing professional education requirements. Please see more information on the Scope of Practice on our website.

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NY Certified Public Accountants are subject to the requirements in A and B:

  1. Either 24 or 40 contact hours of acceptable formal continuing education completed from January 1st through December 31st of each calendar-year (24 if concentrated in one of the recognized subject areas or 40 if in any combination of recognized subject areas); and
  2. 4 contact hours of acceptable professional ethics completed during every three calendar years. These 4 credits of ethics may be counted toward your 24 or 40 CPE credits in the calendar year that you actually complete the ethics course.

See below for more detailed information on these requirements.

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Newly licensed NY State CPAs who were licensed before January 1, 2020 become subject to the continuing education requirements on the January 1st immediately following the last day of their initial registration period. The requirements apply to the first full calendar-year in their second registration period.

Examples for newly licensed CPAs who were licensed before January 1, 2020:

Initial Registration Period Second Registration Period Year MCE Required
1/1/2019 – 12/31/2021 1/1/2022 – 12/31/2024 Jan 1, 2022
6/1/2019 – 5/31/2022 6/1/2022 – 5/31/2025 Jan 1, 2023
12/1/2019 – 11/30/2022 12/1/2022 – 11/30/2025 Jan 1, 2023

Newly licensed NY State CPAs who were licensed on or after January 1, 2020 become subject to the continuing education requirements on the January 1st within their initial registration period. The requirements apply to the first full calendar-year in their first registration period

Examples for newly licensed CPAs who were licensed after January 1, 2020:

Initial Date of Licensure Year MCE Required
January 2, 2020 Jan 1, 2021
June 5, 2020 Jan 1, 2021
December 15, 2020 Jan 1, 2021
January 2, 2021 Jan 1, 2022
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A licensee who claims a medical, military or other hardship adjustment may request an adjustment from CPE requirements if he or she is prevented from practicing. Medical related problems must be certified by a physician. Military adjustments require current military orders. Extreme hardship cases are handled on a case-by-case basis.  To claim the adjustment you must complete Section 3 on the Registration Renewal Addendum found here.

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Attest and Compilation Competency Rules: Any licensee who supervises attest services or signs or authorizes someone to sign an accountant's report on the financial statements of a client for attest services must be in compliance with A, B, and C, and for compilation services be in compliance with B and C:

  1.  
    1. have at least 1,000 hours of experience within the previous five years in providing attest services or reporting on financial statements gained through employment in government, private industry, public practice or an educational institution satisfactory to the State Board for Public Accountancy; or
    2. be employed by a firm registered with the Department pursuant to section 70.8 of the Regulations of the Commissioner of Education that has undergone a peer review satisfactory to the Department which indicates that the firm has received a rating of pass or pass with deficiencies; and
  2. have completed at least 40 hours of continuing education in the area of accounting, auditing or attest during the prior three calendar years or in the calendar year in which the service is performed; and
  3. have maintained the level of education, experience and professional conduct required by generally accepted professional standards, relating to the attest and/or compilations services performed.

The audit partner is ultimately responsible for all the work on the audit, including the tax provision and is required to meet the competency requirements under this rule. The tax partner, or any other partner brought in to assist the audit, is functioning as a consultant to the audit partner and would not be subject to the requirement to obtain 40 hours of CPE in accounting, auditing or attest.

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You do not need to report your CPE compliance on an annual basis. However, on your registration renewal document, you are required to affirm your compliance during the calendar years that ended in the most recently past registration period.

Pursuant to Regulations of the Commissioner of Education, you are responsible for maintaining a record of all the CPE hours you complete. Your records must include the Certificates of Completion as issued by the CPE provider. The certificates must include the following information for each program for which you are claiming CPE credit: your name, the program title, the program sponsor's name, the program sponsor ID number, the subject area, the number of CPE credits awarded, the delivery method, and the program date and location. You must keep these certificates for at least 5 years and they must be made available to the Department upon request.

Monthly, the State Board for Public Accountancy office conducts random audits of licensee CPE records. Failure to produce comprehensive records in a timely manner is grounds for disciplinary action including suspension or revocation of a license and/or fines.

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Yes. To reactivate your registration you will need to certify at a minimum that you completed 24 hours of acceptable CPE in the 12 month period immediately prior to the date you file to reactivate the registration. If you were practicing during the period while you were registered inactive, you may need to complete additional CPE. To return to practice complete Section 4 of the Registration Renewal Addendum found here.

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There is a difference between licensure and registration. In New York, upon satisfying the licensure eligibility requirements, a license is awarded. Licensure is for life unless suspended, revoked or annulled for reasons of misconduct. However, in order to practice as a CPA or PA in New York and use either one of these titles, a licensee must be currently registered.

Based on questions that  the Board has received, it appears that there may be some misunderstandings regarding when a CPA's or a PA's registration is "registered," "inactive" or "not registered." Those terms are briefly described below:

  • Registered – the licensee is "active" and allowed to work within the scope of practice;
  • Inactive – the licensee is not allowed to work within the scope of practice;
  • Not registered - a registration has lapsed without explanation. A licensee is not allowed to work within the scope of practice.

To determine if you are working in the scope of practice, reference the scope of practice document on our website here. Process for Seeking an Inactive Registration Status In order to be granted an inactive registration status, the New York CPA or PA must complete a Registration Renewal Addendum and submit it to the Board Office at cpabd@nysed.gov providing current employment information, including dates of employment, principal place of business, job title, and job description. The Board Office will review the submitted information, make a determination if the New York CPA or PA is or has been working within the scope of practice, and will subsequently grant or deny, in writing, the CPA's or PA's request for inactive registration status.

Mandatory Ethics Requirement
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Any licensed CPA or PA who is subject to the Mandatory Continuing Education requirement. Four (4) contact hours of acceptable professional ethics must be completed every three calendar years. These 4 credits of ethics may be counted toward your 24 or 40 CPE credits in the calendar year that you actually complete the ethics course.

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An individual who is licensed in multiple jurisdictions is required to meet the ethic’s requirement as mandated by the State in which their principal place of business is located. A licensee who is licensed in multiple jurisdictions and whose principal place of business is New York must take a New York State specific ethics course.

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To be acceptable, the ethics course must focus on professional ethics. New York State will not accept behavioral ethics as a substitute for professional ethics. Behavioral ethics will be categorized in the Advisory Services subject area.

If NY State is your principal place of business, only an ethics course that is approved by NYSED is acceptable.

If you are only licensed in NY State, only an ethics course that is approved by NYSED is acceptable.

If your principal place of business is outside NY State, and you are licensed in that state, an ethics course that is provided by any of the following will meet this requirement:

  1. A NY State-registered CPE sponsor that is approved to provide ethics courses.
  2. A NASBA-approved CPE sponsor.
  3. A sponsor that is approved by the licensing authority of the state which is your principal place of business.
Continuing Education Hours
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An hour of continuing education credit is awarded for one contact hour of at least 50 minutes in duration. CPE providers inform participants of the recommended CPE credit for each particular program and provide formal completion certificates awarding the appropriate number of credits to each program attendee.

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CPE credit may be claimed for college-level courses that are within the allowable CPE subject areas. If the college has 15 week semesters, one semester credit equals 15 CPE hours. If the college has 10 week semesters (trimesters or quarters), one credit equals 10 CPE hours. A copy of an official transcript is acceptable documentation of this course work for CPE credit.

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No. Section 7409 of the State Education Law clearly states that the CPE requirement is to be met on an annual basis and that no credits may be transferred from one year to a subsequent year. CPE tracking and reporting runs on a standard January 1 - December 31 year.

Continuing Education Courses and Educational Activities – Acceptable Activities, Subject Areas and Providers
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Acceptable continuing education activities include:

  • Taking a CPE course from a NYS-registered CPE provider.  Click here for the listing of New York State-registered CPE providers. 
  • Taking a CPE course from a NASBA-registered CPE provider. Click here for the listing of the National Association of State Boards of Accountancy (NASBA) registered CPE providers.
  • Taking a CPE course from a CPE provider registered by the State Board for Accountancy in the state in which the course is taken.

The three methods below are only eligible to earn half your annual CPE requirement. Annually, the maximum CPE you can earn from the three methods below is 12 hours, if you are completing 24 contact hours in a single subject area; or 20 hours, if you are completing 40 contact hours in a combination of subject areas.

  • Preparing and teaching a formal CPE course offered by a NYS approved CPE provider, provided that you have not taught the course before. You can claim credit for teaching a course you have taught before only if you significantly revise the information and material you present. You can claim 1 hour of CPE credit for each hour of the actual presentation plus actual preparation time of up to 2 hours of preparation time for each one hour taught.
  • Preparing and teaching a credit-bearing course at a regionally or nationally accredited college or university. Provided that the instruction is in the subject areas set forth in §70.9(c)(2), and you have not taught the course before. You may claim credit for teaching a course you have taught before only if you significantly revise the information and material you present. The content area of the course must fall within the approved subject areas.  The amount of continuing education that will be awarded for teaching a course is 15 contact hours per semester or 10 contact hours per quarter.
    1. If you are completing 24 contact hours in a single subject area, then only 12 contact hours will be allowed.
    2. If you are completing 40 contact hours in a combination of subject areas, then 15 contact hours will be awarded for teaching one course. Additionally, under the combination in any subject area, you may be allowed an additional 5 contact hours, up to 20 contact hours maximum, if you teach more than one course per year.
  • Authoring an article published in a peer-refereed journal or publishing a book in one of the approved subject areas. CPE will be awarded based on article preparation time.
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The seven approved subject areas are specified in the State Education Law §7409(4). They are:

  1. Accounting
    1. Fraud
    2. Internal Controls
    3. Risk Assessment
  2. Auditing
    1. Data Analytics
    2. Fraud
  3. Attestation
  4. Taxation
  5. Advisory Services
    1. Administrative Practice
    2. Behavioral Ethics
    3. Business Law
    4. Business Management & Organization
    5. Communications
    6. Computer Science
    7. Computer Software
    8. Economics
    9. Finance
    10. Information Technology
    11. Management Advisory Services
    12. Marketing: NOTE: Reviewed on a case-by-case basis. Promotional marketing is not accepted
    13. Personal Development
    14. Production
    15. Social Environment of Business
    16. Statistics
  6. Specialized Knowledge and Applications Related to Specialized Industries
    1. Personnel/HR
    2. Special Knowledge and Applications
  7. Professional Ethics
    1. Regulatory Ethics
    2. Ethics and Professional Conduct
    3. State specific ethics

In order to be eligible for CPE credit, regardless of the subject area, a course must contribute to the development or maintenance of professional knowledge. Credit will not be given for courses that focus on the marketing of professional services or improving the profitability of an accounting firm or practice.

Click here for a Detailed Description of CPE Subject Areas. Click here for the NASBA fields of study.

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The Board maintains a list of NYS approved sponsors: Click here to the listing of New York State-registered CPE providers.

NASBA maintains their own list of approved providers: Click here for the listing of the National Association of State Boards of Accountancy (NASBA) registered CPE providers. Other State Boards maintain their own listings.

Information for CPE Providers
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The New York State Education Department will register:

  • A regionally accredited or Regents-approved University or College or division thereof
  • A widely recognized national or state accounting organization, a local chapter thereof, or an educational foundation thereof
  • An accounting firm registered with the Department and presenting in-house programs
  • A group of accounting firms, each of which is registered with the Department, that presents programs offered within the group
  • Another type of organization that provides satisfactory evidence that it has adequate resources and administrative procedures to conduct a formal continuing education program relevant to the practice of public accountancy
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If a provider is a NASBA approved provider, they may offer live courses in NY.

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You must complete the Application for Continuing Education Sponsor Agreement and return it with the application fee to the State Board for Public Accountancy for review. The responsibilities of the registered CPE provider are outlined on the Form CPA 60 included in the application packet.

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A CPE provider is registered for an initial 1 year period. Subsequent registration periods are for 3 years

Last Updated:  February 25, 2020