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Firm Licensing Requirements

Pursuant to § 54.1-4412.1, A, Code of Virginia, only a firm may provide attest or compilation services to persons or entities located in Virginia. Therefore, any licensee or firm providing such services must have a firm license.

This does not prevent an individual not licensed as a CPA from practicing accounting or bookkeeping skills, or rendering tax services. A non-licensee may prepare financial statements as long as no claims of audit, review, or assurance is made on those financial statements, in accordance with § 54.1-4401, Code of Virginia.

Firm Located in Virginia

Pursuant to § 54.1-4412.1, B, Code of Virginia, any firm performing attest or compilation services to persons or entities located in Virginia must hold a Virginia Firm CPA License if Virginia is the principal place of business.

Pursuant to Board Regulation 18VAC5-22-50, reasonable judgment is used in determining whether Virginia is the principal place of business.  The determination considers facts and circumstances and may be based on quantitative or qualitative assessments.

Firm Located Outside of Virginia

Pursuant to § 54.1-4412.1, C, Code of Virginia, any firm whose principal place of business is outside Virginia and is performing attest or compilation services to persons or entities located in Virginia must hold a Virginia Firm CPA License unless the individual providing attest or compilation services has a Virginia Individual CPA License OR is under the supervision of (1) a CPA with a Virginia Individual CPA License or (2) a licensee from a substantially equivalent state or jurisdiction, in accordance with § 54.1-4411, Code of Virginia.

Requirements to Obtain a Firm License

Pursuant to § 54.1-4412.1, D, Code of Virginia, requirements to obtain a Firm CPA License in Virginia include the following provisions.

  • At least 51% of the owners and the voting equity interest of the firm must be CPAs or trustees of an eligible employee stock ownership plan (ESOP).  Owners of a firm who are not licensees must participate in the firm’s activities on a regular, continuous and substantial basis.
  • An individual who supervises firm personnel for attest or compilation services or who releases or authorizes the release of attest or compilation reports must have (1) a Virginia Firm CPA License or (2) a valid Individual CPA License from a substantially equivalent state in accordance with § 54.1-4411, Code of Virginia.
  • An individual who releases or authorizes the release of attest or compilation reports provided for persons in Virginia must annually obtain a minimum of 8 hours of continuing professional education (CPE) related to attest or compilation services, in accordance with subsection A of Board Regulation 18VAC5-22-140.
  • Pursuant to subsection B of Board Regulation 18VAC5-22-140, firms must establish policies and procedures to provide the firm with reasonable assurance that persons who release or authorize the release of reports on attest or compilation services possess competencies that are appropriate given the facts and circumstances which include (at a minimum):


    • Required technical proficiency,
    • Familiarity with the industry and the person or entity,
    • Skills that indicate sound professional judgment, and
    • Other competencies necessary under the circumstances.
  • The firm must conduct its attest and compilation services in conformity with the standards of conduct and practice in accordance with § 54.1-4413.3, Code of Virginia and Board Regulations.
  • The firm must be enrolled in a monitoring program of the American Institute of Certified Public Accountants or another Board-approved monitoring program.
  • The firm’s name must not be false, misleading, or deceptive.
  • All firms applying for CPA licensure must provide a copy of their certificate of incorporation or organization from the Commonwealth of Virginia’s State Corporation Commission. Sole proprietors are exempt from this requirement.