Professional Issues Tracker

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Welcome to the PIT

The Professional Issues Tracker keeps you informed of the legislation, testimony, statements, and thought leadership the PICPA is providing on behalf of all Pennsylvania CPAs and the accounting profession.

This is how we build a better profession.

Peter Calcara and Jen Cryder with bill amending the CPA Law

Happening now

Act 45 of 2025 Brings CNIT Changes for PA Taxpayers

On Nov. 12, 2025, Gov. Josh Shapiro signed House Bill 416 into law, now Act 45 of 2025, as part of the state budget. The law makes significant changes to Pennsylvania’s corporate net income tax (CNIT) by decoupling from several federal provisions enacted under H.R. 1, the One Big Beautiful Bill Act (OBBBA). These changes are projected to preserve more than $1 billion in state revenue, according to the Independent Fiscal Office.

Key changes under Act 45:

  • R&E Expenses: Must be capitalized and amortized over five years for Pennsylvania purposes.
  • Qualified Production Property: Pre-OBBBA depreciation rules continue to apply to this property.
  • Interest Deduction Limitation (IRC Section 163(j)): Pennsylvania will continue using pre-OBBBA rules.

The PICPA State Taxation Steering Committee continues working closely with the Department of Revenue to clarify implementation details. A set of DOR Q&As is available to help you understand compliance and reporting requirements.

The DOR has published a web page offering more details on CNIT decoupling.

Check out the CPA Now blog by James Brower, chair of the PICPA State Taxation Steering Committee, Pennsylvania Decouples from Several OBBBA Business Tax Provisions Affecting C Corporations.

If you have further questions, please contact Peter Calcara, PICPA vice president of government relations.

We are currently tracking 23 issues relevant to the accounting profession.

Legislative Initiatives

See how we're shaping legislation

We are spearheading change to ensure a solid future.

Four students in business attire laughing

Challenges Facing the CPA Profession

Credit requirements, testing, and awareness of the profession affect the future of accounting.

See how we're addressing these challenges

Legislative & Regulatory Initiatives

CPA Licensure and Practice Mobility

The issue

Pennsylvania's CPA licensure law had not been meaningfully updated in decades, despite major shifts in the accounting profession. The previous framework:

  • Required 150 college credits or a master's degree, plus one year of professional experience and passage of the CPA Exam.
  • Created barriers for candidates who had the education and skills but were deterred by time and cost.
  • Limited mobility for CPAs licensed in other states, requiring them to obtain a Pennsylvania certificate and permit before practicing here.
  • Only allowed 18 months to complete all four sections of the CPA Exam.

This structure no longer reflected the realities of today's workforce or the needs of the profession.

Our position

The PICPA championed Senate Bill 719 (now Act 27 of 2025) to modernize CPA licensure while maintaining the profession's high standards and protecting the public. The legislation passed unanimously in both chambers and was signed into law by Gov. Josh Shapiro on June 30, 2025.

Key Updates Supported by PICPA:

New Pathways to Licensure

Pennsylvania now recognizes three routes to becoming a CPA:

  • 150 credits + 1 year of experience + CPA Exam
  • Master's degree + 1 year of experience + CPA Exam
  • New: Bachelor's degree + 2 years of experience + CPA Exam

Additional changes:

  • Candidates may sit for the CPA Exam with 120 credits or a bachelor's degree.
  • Reference letters are no longer required in most cases.
  • Coursework requirements remain the same (24 credits in accounting/auditing, business law, economics, technology, finance, or tax + 12 additional credits in accounting/auditing/tax).

Enhancing Interstate Practice

  • Establishes automatic mobility, allowing CPAs licensed in good standing in other states to practice in Pennsylvania without obtaining a PA license, provided they meet state requirements.
  • Shifts mobility evaluation to the individual licensee level, not the state.
  • Includes guardrails to ensure public protection.

Greater Flexibility for the CPA Exam

  • Expands the exam completion window from 18 to 30 months, giving candidates more time to pass all four sections.
  • Applies retroactively to candidates with unexpired credits as of June 30, 2025.

Why It Matters

Act 27 represents the most significant update to CPA licensure in Pennsylvania in decades. These changes:

  • Reduce barriers to entry while maintaining rigorous standards.
  • Increase workforce mobility and flexibility.
  • Align Pennsylvania with the evolving needs of the accounting profession.

This achievement would not have been possible without the leadership of the PICPA and the unified advocacy of our members.

Act 27 Changes Explained
PICPA comment letter on The CPA Competency-Based Experience Pathway 
     - Dec. 3, 2024
PICPA comment letter on The Uniform Accountancy Act - Dec. 23, 2024
Watch PICPA CEO Jen Cryder explain how exposure drafts can affect CPAs

Reviewed Feb. 2026

Improving Fairness and Flexibility in
Taxpayer Relief Procedures

The issue

Under current law, the Local Taxpayers Bill of Rights only gives local taxing authorities the ability to abate interest and penalties in limited instances, such as when a delay is caused by the taxing authority itself. This leaves no clear remedy for taxpayers who may miss a filing deadline due to serious illness or some other unavoidable disruption. Both Pennsylvania and the City of Philadelphia have broader authority to abate interest or penalties.

Our position

Two legislative proposals backed by the PICPA and its State Taxation Steering Committee seek to expand the interest and penalties abatement authority of local taxing authorities and to require the Department of Revenue to provide taxpayers with a detailed explanation of assessments or adjustments. Both proposals would improve the administration of tax laws in Pennsylvania.

House Bill 855, sponsored by Rep. Joe Webster (D-Montgomery), would amend the Local Taxpayers Bill of Rights to grant local taxing authorities the ability to abate interest or penalty in instances when a taxpayer, acting in good faith, without negligence, and with no intent to defraud the local taxing authority, agrees to pay the remaining balance owed without further appeal. The amendment is intended to assist individual taxpayers and small businesses who inadvertently fail to file a return timely or pay the wrong amount of tax due. 

A companion bill, House Bill 856, also sponsored by Webster, proposes to amend the state Tax Reform Code of 1971 to require that notices of assessment or adjustment contain sufficient information for a taxpayer to understand what is being adjusted and the basis for that adjustment before the period to appeal that assessment or adjustment to the Board of Appeals begins to run. The intent is to provide a taxpayer with enough information regarding an assessment or adjustment to be able to make an informed decision whether to file an appeal. The proposed change will apply for sales and use tax, personal income tax, and corporate tax assessments and adjustments. In addition, House Bill 856 will codify when the six-month refund period begins to run in instances where the Department of Revenue reduces an overpayment to satisfy an adjustment of tax.

By expanding abatement authority and requiring more detailed explanations of assessments and adjustments, the legislation would help ensure that tax enforcement remains fair, especially for taxpayers who are trying to do the right thing under difficult circumstances.

Status: Both bills are pending in the House Finance Committee. 

Reviewed Feb. 2026

CPA Week in Pennsylvania

The issue

Recognizing the vital role that the CPA profession plays in the economy, the PICPA seeks to designate Nov. 17-21, 2025, as Certified Public Accountant Week in Pennsylvania. House Resolution 347 was sponsored by Rep. Ben Sanchez (D-Montgomery) and Rep. Keith Greiner (R-Lancaster) in the Pennsylvania CPA Caucus.

Our Position

The resolution highlights the PICPA, which was founded in 1897 and represents over 18,000 professionals in public practice, industry, government, and education, and emphasizes the essential role CPAs play in Pennsylvania’s economy.

“Our state’s CPAs promote economic growth in Pennsylvania and provide incredibly important financial advisory services to hundreds of thousands of taxpayers and businesses,” the resolution states. “A CPA’s services can especially help business owners by providing consultative services that help business owners navigate their finances and operate their businesses more efficiently. 

Status
House Resolution 347 passed the state House on Nov. 17, 2025, by a vote of 198-4. The PICPA would like to thank Reps. Sanchez and Greiner for their unwavering support and commitment to the CPA Community in Pennsylvania


Reviewed Feb. 2026

2026 Regulatory Agenda: PA DOR

The issue

The Pennsylvania Department of Revenue (DOR) has released its regulatory agenda for 2026.

I. Sales Factor Sourcing Sales of Services
Corporate Net Income Tax (CNIT) - 61 Pa. Code Section 153.26a
Spring 2026, as Proposed

Under section 6 of the Fiscal Code and Section 401 of the Tax Reform Code (TRC), the Department proposes adding Section 153.26a on sales factor sourcing for services. Act 52 of 2013 revised the method for sourcing service revenue in CNIT calculations. The proposed rule establishes procedures for sourcing service income, apportioning business income to Pennsylvania, and ensuring uniform application by taxpayers. 

II. Business Income and Nonbusiness Income
Corporate Net Income Tax (CNIT) - 61 Pa. Code Chapter 153
Final-Form Rulemaking - Spring 2026

Under Section 6 of the Fiscal Code and Section 401 of the TRC (72 P.S. Section 7401(3)), the Department is amending CNIT regulations by adding Section 153.24a on business and nonbusiness income, reflecting legislative changes and evolving U.S. Constitutional case law on states’ taxation of corporations under the Unitary Business Principle. 

III. Payment Methods for Obligations Due the Commonwealth
Amendments (Payment by Electronic Funds Transfer) 
Personal Income Tax (PIT) - 61 Pa. Code Sections 5.1 et seq.
Final-Form Rulemaking - Spring 2026

Under section 9 of the Fiscal Code (72 P.S. Section 9), the DOR and Treasury propose a full revision of Chapter 5 on payment methods for obligations due the Commonwealth. The rule updates allowable payment methods, including cash, check, and various Electronic Funds Transfer (EFT) options, and specifies which obligations must be paid by EFT, and outlines penalties for noncompliance. 

 

Reviewed Feb. 2026

Advisory Opinions from Licensing Boards

The issue

State Rep. Keith Greiner, CPA (R-Lancaster), introduced legislation that would allow licensed professionals to request guidance from licensing boards and commissions under the Department of State regarding the interpretation of laws and regulations.

House Bill 1290 would authorize boards and commissions within the Bureau of Professional and Occupational Affairs to issue advisory opinions in response to inquiries from licensees. These opinions would be nonbinding, but they would give professionals clarity before taking action. According to Greiner, this change could help prevent many unintentional violations by providing licensees a reliable way to confirm whether certain actions are permitted.

Currently, state law does not specifically authorize these boards and commissions to provide advisory opinions. As a result, when professionals seek guidance, boards often respond that they lack the authority to give such direction.

Our position

In March 2024, PICPA CEO Jennifer Cryder, CPA, testified in support of similar legislation last session. The PICPA is urging state lawmakers to adopt the legislation.

Status: House Bill 1290 is under consideration in the House Professional Licensure Committee.

Reviewed Feb. 2026

2026 Regulatory Agenda:
State Board of Accountancy

The issue

The State Board of Accountancy (SBOA) has released its regulatory agenda for 2026.

I. General Revisions
49 Pa. Code Sections 11.16, 11.23a, 11.56, 11.57, 11.82 and 11.84—11.87 (# 16A-5519)
Final Rulemaking - Spring 2026

This proposed rulemaking updates the Board’s regulations to align with recent amendments to the CPA Law. Specifically, it implements changes from Act 110 of 2022 related to CPA examinations, education requirements, verification of experience, and peer review, as well as Act 100 of 2021 requirements for virtual supervision. The rulemaking also establishes a CPE “safe harbor” for licensees supervising attest services, requires licensees who supervise, sign, or authorize the signing of an accountant’s report for attest services to meet competency requirements. In addition, the regulations are amended to allow for continuous testing of the CPA examination, enabling candidates to retake a failed section without waiting for the next testing quarter. The proposed regulation was published on July 12, 2025, with the public comment period ending on August 11, 2025. IRRC submitted comments on September 10, 2025, and the Board is currently reviewing comments and preparing the final rulemaking.

II. Licensure by Endorsement
49 Pa. Code Sections 11.5a and 11.5b (# 16A-5517)
Final Rulemaking - Spring 2026

This rulemaking amends the Board’s regulations to implement the act of July 1, 2019 (P.L. 292, No. 41) (Act 41), which requires licensing boards and commissions to issue a license, certificate, registration, or permit to applicants who hold a current credential from another state, territory, or country with substantially equivalent or more stringent licensing requirements. Applicants must also meet additional criteria established under Act 41. As required, the Board’s regulations address methods for determining applicant competency and establish expiration dates for provisional licenses. The proposed rulemaking was delivered to the Independent Regulatory Review Commission (IRRC) on November 24, 2025, and published in the Pennsylvania Bulletin on December 20, 2025. The public comment period closed on January 20, 2026, and the IRRC comment period closes on February 19, 2026.

Reviewed Feb. 2026

Resident Partner Credit

The issue

Pennsylvania resident partners subject to pass-through entity taxes (PTET) in other states may face double taxation due to the denial of a Pennsylvania resident tax credit. This issue arises even though the taxes paid through PTET to other states are equivalent to those which would otherwise be paid directly by Pennsylvania residents to those other states. The Pennsylvania Department of Revenue (DOR) has stated that resident partners are not entitled to a credit against personal income tax for PTET paid to other states. However, this stance differs from the DOR’s position on resident S corporation shareholders, who are eligible for a similar credit against their personal income tax.

Our position

The PICPA is urging state lawmakers to adopt legislation introduced by Sen. Doug Mastriano (R-Franklin) that extends equivalent credits to resident partners and S corporation shareholders. Senate Bill 253 addresses this inequity and mitigates the risk of double taxation. Reps. Ben Sanchez, CPA-Inactive (D-Montgomery) and Keith Greiner, CPA (R-Lancaster), have also introduced a companion bill - House Bill 1471.

Status: SB 253 was reported from the Senate Finance Committee on April 1, 2025, and is currently before the full Senate. HB 1471 was referred to the House Finance Committee on May 21.

Reviewed Feb. 2026

Optional Entity-Level SALT Cap Workaround

The issue

The federal Tax Cuts and Jobs Act (TCJA) of 2017 imposes a $10,000 limitation on the deduction individual taxpayers may claim for state and local taxes paid for tax years 2018-2025 (SALT cap). This limitation presents challenges for taxpayers, particularly owners and shareholders of businesses structured as partnerships or S corporations. Income generated from the activities of these pass-through entities is currently taxed at the owner level at Pennsylvania’s 3.07% personal income tax rate.

Our position

The PICPA is urging state lawmakers to adopt legislation introduced by Sen. Doug Mastriano (R-Franklin) that provides a revenue-neutral elective pass-through entity tax (PTET). Senate Bill 396 would allow the tax to be paid at the entity level and facilitate the federal deductibility of state income taxes. In doing so, Pennsylvania would align with other states that have already enacted similar legislation to provide their constituents with a path to increased federal tax deductions. To date, 36 of the 41 states imposing a personal income tax have passed similar legislation.

Status: Congress is currently considering options which may extend and/or modify the SALT cap, which may continue to impact Pennsylvania taxpayers. Sen. Mastriano reported in his co-sponsorship memo that over 400,000 pass-through entities file tax returns in Pennsylvania, many of which would benefit from this legislation.

SB 396 was reported from the Senate Finance Committee on April 1, 2025, and is pending in the Appropriations Committee. A companion bill, House Bill 1703, has been introduced by Rep. Keith Greiner, CPA (R-Lancaster).

Reviewed Feb. 2026

A&A and Ethics

A&A

Financial Key Performance Indicators
for Business Entities

The issue

The Financial Accounting Standards Board (FASB) issued an invitation to comment on Financial Key Performance Indicators (KPIs) for Business Entities that will help the FASB determine whether or not to add a project on financial KPIs and, if so, determine the objective and scope of the project.

The wide range of questions cover whether or not financial statement disclosures should include certain FASB-defined KPIs, whether to include nonpublic entities in the scope of the project, and whether an entity that presents KPIs externally should be required to include that KPI along with a related explanation in the footnotes.
Our position

The PICPA does not support providing further measurement and disclosure guidance on KPIs for nonpublic entities. Creating additional prescriptive guidance on these metrics and requiring their disclosure would only add unnecessarily to the volume of disclosures as company-specific metrics will still be provided to stakeholders. Furthermore, not-for-profit entities already provide extensive disclosures related to liquidity in their financial statements. Requiring additional disclosures for not-for-profit entities would be unnecessarily cumbersome and result in increased audit fees, which is not helpful in a time when many not-for-profit entities are experiencing a reduction in funding. In light of the recently completed project on disaggregation of income statement expenses, and the current project on the information provided in cash flow statements, it seems more appropriate to pause consideration of the KPI project and reconsider at a future date after the implementation of the mentioned new standards. 

Other concerns were covered by the following questions:

Question #12 – Should the FASB provide criteria for entities to use to determine when a defined Financial KPI needs to be disclosed? For example, an entity could be required to disclose a Financial KPI that has been defined by the FASB in the financial statements if it presents it or an adjusted version outside the financial statements (for example, if earnings before interest, taxes, depreciation, and amortization (EBITDA) is defined and an entity presents adjusted EBITDA).

Comment – It is unclear how the FASB requirements would extend beyond the financial reporting ecosystem. How would this be monitored if KPIs are issued outside of the established financial reporting system? Would financial statements and audit reports have to be reissued if clients report a KPI subsequent to the financial statements being released? It is unclear how this requirement would practically operate. The need for transparency could be achieved through education regarding best practices and encouraging transparency.  

Question #14 – Should an entity be required to disclose a financial KPI in Generally Accepted Accounting Principles (GAAP) financial statements if the entity communicates the Financial KPI elsewhere? If so, what incremental benefits does requiring (rather than permitting) disclosure provide?

Comment – The PICPA does not support this requirement. The term "elsewhere" is overly broad. In the event that an entity provides certain metrics in its internal financial statements, to the board for example, would they be required to enhance their disclosures in the financial statements? If this is the intended outcome, it is overly burdensome.

Status: On April 30, 2025, the PICPA provided its feedback to the FASB on this invitation to comment.

    Reviewed Feb. 2026

    PCAOB Proposals: Firm Reporting
    and Firm and Engagement Metrics

    The issue

    The Public Company Accounting Oversight Board (PCAOB) issued two proposals that would greatly increase the information firms would be required to report externally, including more detailed fee information, financial and operational information, and policies and procedures that relate to engagements for private company audit clients and for nonaudit services, cybersecurity policies and procedures. The proposals call for a vague and all-encompassing incident report requirement, details on firm governance and structure and the process for making changes to that structure, and a summary description of the firm’s policies and procedures, even for inactive firms. The largest firms also would be required to provide U.S. GAAP financial statements. Many of these proposed requirements would include information related to private company audits and services for nonattest clients, which we believe is outside of the PCAOB’s statutory authority. Proposed engagement and firm metrics include information on time reporting (e.g., average hours worked by partners each quarter), experience of personnel, retention rates, hours spent by senior level professionals on material audit areas, results of internal inspections, restatements, and the use of specialists and shared-service centers, etc.

    Our position

    The PICPA is concerned regarding the magnitude and granularity of the proposed requirements. The costs of compliance would be astronomical and would not contribute to improving audit quality. Instead, they would further strain the pipeline and challenge the already constrained talent pipeline. The PICPA also argued that investors would not have sufficient context to understand many of the proposed metrics, including the results of a firm’s internal inspection findings. While the PCAOB’s proposal is predicated upon the need to provide investors with additional information to assist in their ratification of the auditor, in many cases investor votes on ratification are nonbinding. We believe that audit committees already access much of this information, and this required reporting disintermediates the role of the audit committees. 

    Status:     After making some revisions based on feedback received, the PCAOB voted to adopt the new standards in late November of 2024 and forwarded them for Securities and Exchange Commission approval. The PICPA responded to the SEC on both of the proposals and met with Congressman Dan Meuser’s (R-Pa.) office to encourage the SEC to extend the response deadline into the next administration. On Jan. 10, 2025 the SEC extended the comment period to Feb. 4, 2025. On Feb. 11, 2025, the PCAOB withdrew the originally approved rules.

    Reviewed Feb. 2026

    Alternative Practice Structures
    and Private Equity

    The issue

    As firm ownership models grow more complex—including private equity, technology investors, sovereign wealth funds, and other capital structures—the National Association of State Boards of Accountancy (NASBA) is evaluating the implication of these investments on the public interest, firm independence, governance structures and audit quality. The NASBA Private Equity Task Force White Paper on Alternative Practice Structures (APS) and Private Equity signals increased regulatory attention.

    Our position
    PICPA submitted a formal response to the white paper with a clear message: we support strong regulation that protects the public but oppose changes that create unnecessary burden or inconsistent rules.

    1. Support for Modern, National Standards—Not a Patchwork of State Rules
    PICPA urges NASBA to pursue nationally consistent standards through existing standard-setting and regulatory bodies. State-by-state regulation has not kept pace with evolving ownership models and would create unnecessary compliance challenges. A patchwork of rules increases cost, risk, and administrative burden for firms of all sizes and undermines firm and professional mobility.

    2. Opposition to New State-Specific Independence, Disclosure, or Oversight Requirements
    PICPA emphasizes that current frameworks—the American Institute of Certified Public Accountants (AICPA) Code of Professional Conduct, Quality Management standards, and the national peer review program—already provide strong safeguards for audit quality and independence. These systems should be evolved, not duplicated at the state level. New state-level rules would add operational burden without improving audit quality or public protection.

    3. Framing Alternative Practice Structures (APS) as “Complex Ownership Structures,” Not Just Private Equity

    PICPA stresses that APS encompasses a wide range of ownership and financing arrangements beyond private equity. Regulation should reflect the full scope of complex ownership structures, rather than focusing narrowly on a single capital source. A private equity-only focus risks outdated or ineffective regulation and fails to address broader, long-term shifts in the profession.

    PICPA is proactively advocating for regulation that protects the public while recognizing the evolving reality of firm ownership. Our position is clear:
       • Regulation must keep pace with changing ownership models—not just private equity.
       • Changes should occur within existing national standard-setting and regulatory frameworks.
       • Protecting audit quality and ethical standards remains paramount.

    Status: Our comments on the NASB Private Equity Task Force White Paper - Alternative Practice Structures & Private Equity: Considerations and Questions were submitted on Jan. 29, 2026.

      Reviewed Feb. 2026

      Increasing Investor Access
      and Facilitating Capital Formation

      The issue

      The U.S. House Committee on Financial Services held hearings on Feb. 26, 2025 regarding legislative proposals to increase investor access and facilitate capital formation. Feedback was requested on four areas: access to capital, investor access, public markets and company lifecycle, and technology and artificial intelligence in capital markets. PICPA provided feedback to the questions related to public markets and company lifecycle and technology and artificial intelligence in capital markets. 

      Our position

      Our primary concerns related to increasing costs and compliance burden stemming from recent Public Company Accounting Oversight Board (PCAOB) actions and the impact of these pressures on small firms in particular. We support changes at the SEC and PCAOB that will reduce the regulatory burden that increases costs unnecessarily and discourages small and mid-sized audit firms from auditing small public companies.

      Status: The PICPA submitted a response to the U.S. House Committee on Financial Services.

      Listen to this summary from Allison Henry, vice president of professional and technical standards.

      Reviewed Feb. 2026

      PCAOB Proposed Rule on NOCLAR

      The issue

      The Public Company Accounting Oversight Board's (PCAOB) noncompliance with laws and regulations (NOCLAR) proposal would fundamentally change the nature and scope of the audit by proposing to change the auditor’s responsibility for identifying noncompliance with laws and regulations. These responsibilities would be greatly expanded to include those agencies having an indirect impact on the financial statements or operational compliance such as EPA, OSHA, FDIC, FDA, FCPA, and AML on privacy laws, tax laws, and consumer protection laws.

      Our position

      The PICPA is vigorously advocating against the untenable expansion of the scope of the audit proposed by the PCAOB. Legislative outreach efforts are in progress. PICPA members are strongly encouraged to reach out to their state congressional representatives — U.S. Reps. Mike Kelley, Brian Fitzpatrick, and U.S. Sen. John Fetterman — to make them aware of this significant issue.

      Status: The PCAOB has delayed action on the proposed NOCLAR standard after strong feedback from audit firms and stakeholders, including the PICPA.

      • Outreach to U.S. Rep. Brian Fitzpatrick to schedule a meeting - July 9, 2024 
      • Outreach to U.S. Reps. Bill Huizenga (MI), Ann Wagner (MO), and Dan Meuser (PA) - Sept. 4, 2024
      • PICPA Met with Rep. Huizenga’s staff to discuss concerns over the NOCLAR proposal and the aggressive PCAOB agenda, as well as Huizenga’s previous proposal to fold PCAOB into the SEC. - Sept. 27, 2024

      Reviewed Feb. 2026

      Charter School Audit Requirements
      - Act 55 of 2024

      The issue

      Senate Bill 700, signed into law as Act 55, on July 11, 2024, is an omnibus measure that introduced numerous amendments to the Pennsylvania School Code. Among its provisions are new audit requirements that raised concerns for PICPA upon review.

      Our position

      PICPA analyzed the legislation and identified several key issues, particularly provisions that appear to conflict with current professional auditing standards. 

      Status: In early 2025, PICPA developed and distributed an Issue Brief outlining our concerns. The brief includes illustrative examples related to government auditing standards, scope of work, and audit boundaries. It was shared with the Pennsylvania Department of Education and relevant members of the Pennsylvania General Assembly and other key stakeholder groups.

      Reviewed Feb. 2026

      Proposed Regs Governing Practice Before the IRS

      The issue

      Treasury Department Circular 230 (Circular 230) provides guidance for attorneys, certified public accountants (CPAs), enrolled agents (EAs), enrolled retirement plan agents, and other persons with representation rights before the IRS (31 C.F.R. Part 10). Circular 230 was last revised in June 2014, and many legal, economic, and technological changes have occurred that affect practice before the IRS since the last revision. The proposed regulations (REG-116610-20) seek to update Circular 230 and harmonize those regulations with changes in law.

      Our position

      We support Treasury’s efforts to modernize Circular 230 regulations, but believe significant changes are needed before these important regulations are finalized. Key areas of concern include:

      • Broad language that does not include materiality consideration
      • Potential restrictions on contingency fees
      • Regulatory control over fees
      • Best practice guidance that is misguided (focusing on understanding the risks and benefits of all technology tools used), too detailed (data security and incidence reporting and business continuity and succession planning), and potentially impossible to implement (e.g., taking action in the event of a practitioner’s mental impairment)
      • Subjective behavioral guidance
      • Other
      We believe that the proposed revisions have been rushed and that the comment period should be extended past the April 15, 2025, tax-filing deadline to ensure that there is adequate time for due process. Additional time is needed for a more thorough analysis of other sections (e.g., appraisers). These regulations have a significant impact on practice, and it is important to ensure that they are sufficiently robust without going beyond what is legally permissible. Further analysis is required to determine the potential impact on practice standards and compliance requirements, to correct and/or clarify vague enforcement provisions, and to delete provisions that overreach regulatory authority, are arbitrary, or can be inconsistently applied. Further consideration is also needed to ensure that there are adequate guardrails surrounding unlicensed, unenrolled tax practitioners.

      Status: The PICPA has submitted a response to the Treasury Department expressing our concerns regarding the proposed rules and requesting an extension of time for improved due process.

      Reviewed Feb. 2026

      PCAOB Inspection Results
      and Enforcement Actions 

      The issue

      Recent Public Company Accounting Oversight Board (PCAOB) inspection reports reveal exaggerated deficiency levels that contradict the positive trends in audit quality. The PCAOB’s 2023 report shows 46% of reviewed engagements had at least one significant Part I.A deficiency, meaning firms lacked sufficient evidence to support their audit opinions. U.S. Sens. Elizabeth Warren and Sheldon Whitehouse described the results as “astonishing” and urged the PCAOB to take significant actions.

      Our position

      We disagree. Although audit quality can improve, PCAOB’s pass/fail model does not provide a full picture. Changes to PCAOB’s inspection reports are necessary. Similarly, the rise in enforcement action is concerning, and it may worsen talent acquisition pressures due to a hostile regulatory climate.  

      Status:

      • Enforcement vs. progress: Audit reform amid heavy regulation, written by PICPA’s Allison Henry, highlights the disconnect between improvements in certain key audit metrics (e.g., restatement trends) and extreme PCAOB enforcement actions. The article discusses the negative impact of regulatory overreach on the profession, the talent pipeline, and the public trust. – Oct. 18, 2024

      • PICPA proposes revisions to the PCAOB’s inspection reports to better articulate the degree of severity of the inspection findings. – Oct. 30, 2024

      Reviewed Feb. 2026

      Quality Control Standards

      The issue

      On May 13, 2024, the Public Company Accounting and Oversight Board adopted A Firm's System of Quality Control and Other Amendments to PCAOB Standards, Rules, and Forms. The PCAOB adopted a standard that it believes will lead registered public accounting firms to significantly improve their Quality Control (QC) systems. An effective QC system protects investors by facilitating the consistent preparation and issuance of informative, accurate, independent, and compliant engagement reports. Properly conducted audits and other engagements enhance the confidence of investors and other market participants in the information firms report on.

      Our position

      We support rigorous audit quality and the modernization of audit standards that will achieve that end. Thus, we believe that the proposed standards should be weighed against the overall objective of improving audit quality and the expected costs. We are concerned that this proposal will not improve audit quality, but instead will reduce competition, increase audit fees, and introduce conflicts with international standards.

      Status: The PICPA issued a comment letter to the U.S. Securities and Exchange Commission on June 24, 2024.

      Reviewed Feb. 2026

      Ethics

      Collective Investment Vehicles and Pension Funds
      – Auditor Independence 

      The issue

      The consultation paper notes that there is a concern that "the Code’s definitions of 'audit client' and 'related entity' might not capture certain parties that are (a) responsible for decision-making and operation of the Scheme, (b) able to substantially affect the financial performance of the Scheme, or (c) in a position to exert significant influence over the preparation of the Scheme’s accounting records or financial statements (hereinafter referred to as 'connected parties')." They are concerned that management and those charged with governance are delegating key responsibilities to these connected parties.

      Their proposal would require an auditor to evaluate his/her independence with respect to "connected parties," such as investment advisors, external fund managers, and others.
      Our position

      We fundamentally disagree with their underlying premise and do not believe that there is a need to augment the independence standards. We do not believe that the audit standards would permit auditors to take on an engagement in which management does not agree to assume key management responsibilities. We therefore do not believe that the independence standards need to be expanded to consider "connected parties".

      Status: The PICPA issued a comment letter to the IESBA on June 25, 2025

      Reviewed Feb. 2026

      Licensure and Pipeline

      Recognizing Accounting Programs as Professional Degree Programs

      The issue

      The U.S. Department of Education is considering changes to how “professional degree programs” are defined for federal financial aid purposes. Draft regulatory language could exclude accounting programs from this designation, despite the rigorous education, examination, and licensure requirements needed to become a CPA.

      Excluding accounting from professional degree recognition would limit access to financial aid for students, weaken the CPA pipeline, and create additional barriers at a time when demand for accounting professionals continues to grow.

      Our position

      PICPA supports the formal recognition of accounting programs as professional degree programs. As part of a growing coalition led by the AICPA and national and state professional accounting organizations, PICPA is urging the U.S. Department of Education to explicitly include accounting in the upcoming proposed rule.

      Recognizing accounting as a professional degree reflects the complexity and public interest role of the CPA profession, helps ensure equitable access to education, and supports the long-term strength of the accounting workforce.

      National Organizations Letter

      National Organizations Release

      State Society/AICPA Letter

      Reviewed December 2025

      Work and Learn

      The issue

      According to research conducted by the Center for Audit Quality (CAQ) and PICPA, the significant time and cost associated with the pursuit of 150 credit hours of education in order to get the CPA license is a barrier for those considering a career in accounting. The additional 30 credits beyond a bachelor’s degree is leading many candidates to reconsider their choice of career or delay pursuing licensure.

      Our position

      Providing work-and-learn programs and opportunities offers a practical, feasible solution to help grow the accounting profession. The PICPA is helping to facilitate these programs and encouraging higher education institutions and firm leaders to adopt these programs.

      Download the Work-and-Learn Toolkit
      For Higher Education and Public Accounting Firms

      Work-and-Learn Models for CPA Candidates: Taking Action to Eliminate Barriers
      by PICPA CEO Jennifer Cryder, CPA, MBA

      Pennsylvania CPAs Try Out Work-and-Learn Model
      Accounting Today

      Reviewed April 2025

      CPA Exam Window Extension

      The issue

      To increase the accounting pipeline capacity and remove further barriers to entry within the industry, it's important to rethink the 18-month window to pass all parts of the CPA Exam.

      Our position

      The PICPA supports extending the exam window from 18 to 30 months. In addition to our support of reinstating credits for exams lost during the pandemic, the PICPA has encouraged the State Board to adopt the new suggested window of time for future candidates to complete their exam.

      Status: Approved

      Update: Regulations are unlikely to be adopted until mid-2025, and the PICPA continues to work with stakeholders and policymakers on this issue. We encourage any candidates who currently meet the requirements to continue to apply for extensions as needed.

      A Win for the Profession: The Importance of NASBA's CPA Exam Window Extension
      by PICPA CEO Jennifer Cryder, CPA, MBA

      NASBA approves one-year extension to CPA Exam window
      Journal of Accountancy

      Reviewed April 2025

      NPAG Report and Pipeline Promise

      The issue

      The National Pipeline Advisory Group (NPAG) was created to develop a unified strategy that reflects the needs of multiple stakeholders, leverages unbiased research, and leads to meaningful change. The Advisory Group is focused on boosting awareness of the profession’s vital role, driving innovative pipeline strategies, and ensuring the next generation of accountants is prepared for tomorrow’s challenges. The NPAG reflects diverse perspectives from across the profession.

      Our position

      The PICPA supports NPAG's findings and report. We're encouraging our members to take the Pipeline Pledge, an individual commitment to participate in two activities of your choosing that can influence and grow the talent pool.

      Read the Final Strategy Report
      NPAG

      Reviewed April 2025

      CPA Credit Relief Initiative

      The issue

      In response to significant health, economic, education, and travel disruptions resulting in CPA Examination candidate hardships, extensions were proposed for any CPA Examination credits that expired from Jan. 30, 2020, through May 11, 2023.

      Our position

      The PICPA supports the Credit Relief Initiative and encourages the Pennsylvania State Board of Accountancy to adopt the policy. We also encourage all of our CPA candidate members to apply for credit relief by the March 31 deadline.

      Status: Passed December 2023

      Update: 223 Pennsylvania candidates received credit for lost exam sections restored.

      Reviewed April 2025

      The Profession and Long-Term Human Capital Strategy

      The CPA Pipeline Crisis

      The issue

      The pipeline challenges the profession are facing are reflective of the fact that relevance of CPAs are in question. Firms must lean on business model transformation to fix the relevance problem and thus pipeline. Firms are struggling to attract new talent, keep their Gen 2 or Gen 3 around, and grow their practice.

      Our position

      The PICPA believes it is critical that business owners and executives in the accounting profession look inward and plan for significant adjustments to address our current pipeline and quality challenges. Firms must look at how their current model is set up and determine if it's time to change. The next generation of CPAs must be provided with more to unlock their potential and keep them interested. Firms can do this by building more distinct career paths, adding new revenue opportunities or client services and automating or digitizing their business. This will give employees a greater sense of purpose while increasing revenue channels. Clients have come to value CPAs as business advisors and not just bookkeepers. By expanding client services to encompass consulting, mergers and acquisitions, and more, accounting firms can better support their CPAs, fostering professional growth and development. Such a diversified service portfolio allows these firms to cross-sell to clients, strengthening client relationships and ensuring long-term business sustainability. The tech-savvy generations coming into the profession are increasingly drawn to career paths that promise innovation and technological advancement, and presenting accounting in this light will be a significant draw. CPA firms must also rethink their equity and compensation strategy. Rethinking an entire business model and implementing meaningful changes won't happen overnight, but the conversation needs to be had before it is too late.

      Why the CPA Profession Needs to Overcome its Challenges Quickly and Collaboratively
      by PICPA CEO Jennifer Cryder, CPA, MBA

      The Evolving Role of State Societies
      The Unique CPA Podcast

      Why the CPA qualification’s 150-hour college credit rule is outdated–and inequitable
      Fortune

      Despite Record Profits, Accounting Firms Must Change Business Models. Here’s Why…
      by PICPA CEO Jennifer Cryder, CPA, MBA

      Reviewed November 2025

      Dual Enrollment

      The issue

      Early exposure to accounting is proven to be influential to students choosing majors and future career plans. There is also significant cost associated with obtaining a college degree and, specifically, the additional credits needed for a CPA license. Offering high school students the chance to enroll in a college accounting course not only introduces them to exciting curriculum, but also offers an affordable way to begin obtaining college credits.

      Our position

      The PICPA has partnered with Outlier to offer a 3 credit, completely virtual asynchronous Intro to Accounting Course through the University of Pittsburgh, paid for by the PICPA. Students participating in the program have a support person at their school who can provide direction through proctoring exam and adhering with course timeline.

      Update: 64 students are enrolled in this program for the 2024-2025 school year. Notably, more than half of these participants lacked access to accounting coursework within their own educational institutions.

      Why the CPA Profession Needs to Overcome its Challenges Quickly and Collaboratively
      by PICPA CEO Jennifer Cryder, CPA, MBA

      PICPA and Outlier Bring College Accounting to High Schools
      by Matt Greene and Kristen Wilbert • CPA Now Blog

      Reviewed November 2025

      Press Releases

      PICPA - Pennsylvania Institute of CPAs

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