Reciprocity: The Complete 350 Q&A
Guide to Practice Privilege, the Third
Pathway, CPE, Peer Review, and
Board Regulations (2025–2026
Updates)
Q1: What is the Maryland CPA Reciprocity Exam?
A1: There is no separate "Maryland CPA Reciprocity Exam." Maryland
grants out-of-state CPAs a practice privilege (or reciprocal license) based
on their existing credentials, primarily requiring that they passed the
Uniform CPA Examination to qualify for their home state license. No
additional exam is required .
Rationale: Maryland eliminated the additional testing barrier to address the
CPA shortage and streamline mobility, recognizing the Uniform CPA Exam
as the consistent competency benchmark .
Q2: What is the most significant change to Maryland's reciprocity laws
effective October 1, 2025?
A2: The primary qualification for practice privilege shifted from requiring
the home state's licensure requirements to be verified by NASBA as
"substantially equivalent" to the Uniform Accountancy Act, to simply
,requiring that the out-of-state CPA passed the Uniform CPA
Examination to qualify for their license .
Rationale: As some states allow candidates to sit for the CPA Exam with 120
credit hours (rather than 150), maintaining the exam as the consistent
competency standard preserves professional rigor while accommodating
state-level variations in education pathways .
Q3: What legislation enacted this change?
A3: Senate Bill 51 (also cross-filed as House Bill 887), sponsored by Senator
Ellis, passed both chambers unanimously and was signed into law as
Chapter 407 .
Rationale: The unanimous passage reflects broad industry consensus that
mobility reform benefits the profession and addresses the talent shortage
without compromising public protection .
Q4: When does SB 51 take effect?
A4: October 1, 2025 .
Rationale: October 1 is the standard default effective date for most
Maryland legislation, providing the Maryland Board of Public Accountancy
with sufficient lead time to prepare internally—including updating
processes and systems .
Q5: Does an out-of-state CPA need a Maryland license to practice in
Maryland?
A5: No. Under the practice privilege (mobility), an out-of-state CPA whose
principal place of business is outside Maryland is exempt from Maryland's
licensing requirement under §2-301 .
,Rationale: The exemption eliminates redundant licensing while ensuring
CPAs remain accountable to the Maryland Board through consent
provisions .
Q6: What are the two main qualifications for the out-of-state practice
privilege under the new law?
A6: (1) Holding a valid CPA license from another state; and (2) having been
required to pass the Uniform CPA Examination to qualify for that license .
Rationale: These two conditions ensure both current licensure status and
demonstrated core competency through the national examination
standard .
Q7: What was the old standard that SB 51 replaced?
A7: The previous standard required the home state's requirements to be
"verified by NASBA as substantially equivalent with the licensure
requirements of the Uniform Accountancy Act" .
Rationale: The old standard created barriers when states adopted varied
education pathways, particularly allowing 120-hour exam sitting while the
UAA recommended 150 hours for licensure .
Q8: Why did Maryland change the reciprocity standard?
A8: To remove unnecessary barriers for experienced CPAs relocating to
Maryland, address the anticipated accounting professional shortage, keep
Maryland competitive, maintain consumer protections through Board
oversight, and adapt to evolving national CPA standards .
Rationale: The "one-size-fits-all model no longer reflects today's
professionals"; the change allows flexibility while preserving rigor .
, Q9: Does the new law change Maryland's education requirements for
initial licensure?
A9: No. SB 51 specifically addresses out-of-state CPAs practicing in
Maryland. Maryland's initial licensure education requirements (150
semester hours) remain in place, though a "third pathway" with 120 hours
plus 2 years experience takes effect October 1, 2026 .
Rationale: The distinction between reciprocity and initial licensure ensures
mobility for experienced out-of-state CPAs while allowing Maryland to
gradually modernize its own pathways .
Q10: What is the effective date for Maryland's "third pathway" to
initial licensure?
A10: October 1, 2026 .
Rationale: The phased approach provided lead time for Board
implementation and stakeholder education, following a "thoughtful, two-
step approach" starting with inbound mobility reform .
Q11: What is the "third pathway" to Maryland CPA licensure?
A11: A bachelor's degree (120 semester hours) with required accounting
coursework, passing the CPA Exam, plus two years (2,000 hours per year) of
relevant professional experience .
Rationale: This pathway shifts more of the development journey into the
workplace, creating employer opportunity and responsibility for mentoring
and training, making licensure accessible to a more diverse population .
Q12: What are the other two pathways to Maryland CPA licensure?