As CPA licensure pathways continue to evolve across the country, many institutions are asking an important question:
Does our accounting program count as a licensure program under Title IV regulations and SARA Policy 5.2?
It is a fair question, and one that has become more complex in light of recent regulatory guidance and state-level changes for CPA licensure.
Below, HELP experts break down what is changing in CPA licensure, where federal regulations come into play, and how institutions should think about risk when determining their compliance approach.
First: What Is Changing in CPA Licensure?
As discussed in our recent webinar, Reconsidering Accounting Programs: Changes to CPA Pathways to Licensure, states are adopting new pathways under what is often referred to as “CPA Evolution.”
Historically, most states required:
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A bachelor’s or post-baccalaureate degree
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150 total semester credit hours
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Specific accounting and business coursework
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Approximately one year (2,000 hours) of experience
Under new pathways, many states now allow alternatives such as:
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A bachelor’s degree plus two years of experience
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A graduate degree plus one year of experience
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A bachelor’s degree plus 30 additional credits plus one year of experience
At the same time, individual states continue to maintain detailed, credit-specific coursework requirements. For example:
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Utah’s revised pathway (effective July 1, 2026) maintains defined accounting and business subject areas
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Kansas still requires 150 credits plus specific economics, business law, analytics, and accounting coursework
The takeaway is simple: CPA requirements remain state-specific, detailed, and in motion.
That complexity matters when Title IV regulations (34 CFR § 668.43 and 34 CFR § 668.14(b)(32)) and SARA Policy 5.2 enter the picture.
The Federal and SARA Overlay: When Does an Accounting Program Become a “Licensure Program”?
Under 34 CFR § 668.14(b)(32), institutions must determine whether a Title IV-eligible program:
“Satisfies the applicable educational requirements for professional licensure or certification requirements in the State…”
Additionally, 34 CFR § 668.43 requires public disclosures if a program is designed to meet, or is advertised as meeting, licensure requirements .
If a program does not meet the requirements in a student’s state (or the institution has not made a determination), individual direct disclosures are required before enrollment.
So how does this apply to accounting?
The key question is whether the program is designed or advertised as preparing students for CPA licensure.
The Source of Confusion
Some institutions point to ED Certification Procedures Questions & Answers guidance, suggesting that accounting programs are not automatically considered licensure programs unless CPA licensure is required for employment as an “accountant.”
And, indeed, most states do not require CPA licensure for general accounting employment.
However, employment as a CPA does require licensure in all states.
This is where institutional interpretation and risk tolerance come into play.
A Practical Compliance Framework
Based on regulatory text, preamble guidance, and direct communication with ED staff in 2024–2025, here is how we encourage institutions to think about it:
If your accounting program is advertised or designed specifically to prepare students for CPA licensure:
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It should likely be treated as a licensure program.
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You must make state-by-state determinations for distance education students based on location at the time of initial enrollment.
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You must provide the required public disclosures.
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If the program does not meet educational requirements in a student’s state, the student cannot enroll without appropriate written attestation completed before enrollment.
Remember that “distance education student” is broadly defined. If a student takes even one online course in the first term of the licensure program, that can trigger location-based analysis.
If your accounting program is not marketed or positioned as CPA preparation:
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You may determine that it is not a licensure program.
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However, this determination should be carefully evaluated in light of your website language, recruitment materials, and program descriptions.
Marketing language matters.
The Risk Analysis Institutions Must Consider
Ultimately, this is not only a question of regulatory interpretation. It is also a risk question.
Consider:
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How many of your graduates intend to sit for the CPA exam?
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How many of your students are distance education students?
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How frequently do graduates relocate across state lines?
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How likely is it that a graduate could be deficient in required coursework for the state where they plan to seek employment?
Online programs have greater variability in student locations and, therefore, often pose a higher compliance risk.
Institutions with small percentages of CPA-intending graduates may evaluate that risk differently than programs explicitly branded as CPA preparation tracks.
There is no one-size-fits-all answer. There is only a documented, defensible compliance approach aligned with your institutional risk tolerance.
The Bigger Picture
The goal of the federal licensure disclosure regulations is to ensure that students are not enrolling in programs that will not meet the educational requirements necessary for licensure in the state where they are located.
Because employment as a CPA requires licensure, programs that explicitly prepare students for CPA licensure lean toward inclusion under these rules.
At the same time, evolving state pathways and shifting credit models mean institutions must continuously monitor changes.
This is not a static compliance exercise. And one that The Bookmark can support.
Final Thought
If your accounting program references CPA preparation, now is the time to:
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Review marketing language
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Evaluate your state-by-state determinations
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Confirm your distance education location tracking processes
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Document your compliance rationale
As CPA licensure pathways evolve, institutions must align both academic design and regulatory strategy.
How HELP Supports This Work
The Bookmark was built for exactly this kind of complexity. Our one-of-a-kind database provides:
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Regularly updated CPA educational requirements for all U.S. states and territories
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Structured information for comparisons to support “meets” and “does not meet” determinations
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Research reviewed by experienced licensure and legal researchers
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A centralized, defensible source of truth for Title IV and SARA compliance
Instead of relying on fragmented spreadsheets or manual board-by-board research, institutions use The Bookmark to make clear, documented determinations with confidence.
As CPA licensure pathways continue to evolve, compliance decisions should not be reactive or based on guesswork. They should be informed, documented, and aligned with your institutional risk tolerance.
If your accounting program references CPA preparation, now is the time to review your disclosures and determinations.
Join an upcoming info session to see how The Bookmark supports state-by-state CPA compliance with clarity and confidence.
Accounting Resources
National Association of State Boards of Accountancy (NASBA)
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