Montana CPA CPE Requirements

How to reach the regulator directly.

Montana Board of Public Accountants
301 South Park, 4th Floor
P.O. Box 200513
Helena, MT 59620-0513

Tel: (406) 841-2205
Fax: (406) 841-2309

Email: DLIBSDLicensingUnitA@mt.gov

The regulator's own published rules and related resources.

Montana Board of Public Accountants

The total continuing education hours required.

120 hours.

The detailed rules behind that total -- category minimums, ethics, and other conditions.

Technical Subject Requirement:

Effective December 9, 2017: Beginning with periods starting January 1, 2018 and after, active licensees must complete a minimum of 50 percent (60 hours) of the total CPE hours required in technical fields of study as identified in ARM 24.201.2120 (refer to "General Characteristics of Accredited Education" below). Subjects other than technical and nontechnical fields of study may be acceptable if the licensee can demonstrate to the board's satisfaction that such subjects or specific programs contribute to the maintenance of the licensee's professional competence.

• January 8, 2018: Note from CeriFi: The MT Board has confirmed that the new technical requirement will not be audited until the 2018 - 2020 reporting period. However, licensees should be aware of this new requirement beginning in 2018 and ensure that they earn technical credits in 2018 and 2019. The MT status report has been updated to display 'technical' and 'non-technical' subjects so that licensees can track this requirement ahead of when it will first be due. In other words, licensees must have 50% of their total credits earned in 'technical' subjects for the January 1, 2018 - December 31, 2020 CPE period.

Ethics:

Effective November 21, 2014 (Updated June 4, 2016): Active licensees are required to have 120 hours of continuing professional education (CPE) with a subset of two hours in ethics for the previous three-year period ending December 31 of each year, except as otherwise provided an Extension or Hardship Exception.

• Note from CeriFi: October 1, 2019: The MT Board has confirmed that the Board does not further specify the ethics requirement. The Board will accept either regulatory ethics or behavioral ethics to fulfill the 2-hour ethics requirement. The 2 hours of ethics will also count toward the 50% technical requirement. in the event a licensee earns more than 2 hours of ethics, the excess ethics will be considered technical education and count toward the technical subjects requirement.

Effective July 13, 2012 - November 20, 2014: Holders of a Montana permit to practice are required to have 120 hours of continuing professional education (CPE) with a subset of two hours in ethics in any rolling three-year period.

Prior to July 13, 2012: At least two hours of the 120 hours of acceptable continuing education credit must consist of knowledge and the application of ethics or the codes of professional conduct of certified public accountants and licensed public accountants.

Reporting on Financial Statements Requirement: [RESCINDED]

For periods ending June 30, 2005 and earlier: At least 24 hours of the 120 hours of acceptable continuing education credit must consist of subjects related to the reporting on financial statements (as defined in ARM 8.54.204).

• NOTE: CeriFi has confirmed that this rule no longer applies to periods ending June 30, 2006 and after.

How the reporting cycle is structured.

Effective July 13, 2012 (Updated November 21, 2014): Beginning with the 2012 period, the rolling three-year period will be based on the calendar year. To make the change from fiscal year to calendar year, licensees will be able to count CPE obtained between July 1, 2011 through December 31, 2012, toward the 2012 year.

• Understanding the Rolling Three-Year Period Under the New CPE Rules: Even though you have a rolling three-year period to meet the basic CPE requirement of the Board, it helps to think of CPE being earned on a yearly basis in order to understand the change from a fiscal year to a calendar year and how that effects the three-year period.
• Through 2011, CPE was earned on a state fiscal year (July 1st through June 30th). To accommodate the change to a calendar year, the Board has extended the 2012 year to 18 months (July 1, 2011 through December 31, 2012). Beginning in 2013, CPE will be earned on a regular calendar year (January 1st through December 31st).
• Until the three-year period ending 2015, when all three years (2013, 2014 and 2015) are on the regular calendar year, you should refer to the paragraph above in order to calculate the dates of the rolling three-year period. To break it down, these are the parameters of those rolling three-year periods between now and 2015:

When a reporting cycle begins.

Effective July 13, 2012: January 1. Beginning with the 2012 period, the rolling three-year period will be based on the calendar year. To make the change from fiscal year to calendar year, licensees will be able to count CPE obtained between July 1, 2011 and December 31, 2012, toward the 2012 year. (Refer to "Cycling Period" above.)
Prior to July 13, 2012: July 1.

How completed credits are reported to the regulator.

Renewals / Reporting Requirements:

1. Renewal licenses will be issued by the board to all certified public accountants and licensed public accountants eligible for renewal upon submitting the complete renewal form, and payment of the established renewal fees.
2. All firms must annually register with the board by December 31. Annual registration must include all of the items of a new firm registration and the level and type of public accounting services provided since the last firm registration.

Active licensees will be required to affirm their compliance with understanding of the basic requirement upon annual renewal. This affirmation will be for the three calendar years immediately preceding the renewal year.

Effective July 13, 2012; Updated November 21, 2014; June 4, 2016; December 8, 2018: Reporting of actual courses/credits is not required, unless the individual is selected for a random CPE audit (as outlined in ARM 24.201.2148), or the individual must otherwise prove compliance for licensure purposes (i.e., restoring a license to active status).

Standards for CPE Reporting:

Effective December 9, 2017; Updated December 8, 2018: Licensees are responsible for accurately reporting CPE and must retain appropriate documentation of their participation in learning activities.

Updated November 21, 2014; December 9, 2017; December 8, 2018: Participants in group, self-study, nano-learning, or blended learning programs must obtain a certificate of completion or transcript issued by the program sponsor. Acceptable documentation must include the following information:

1. participant's name;
2. sponsor;
3. course title and/or description of content;
4. date(s);
5. location;
6. number of continuing education credit hours granted; and
7. Effective July 13, 2012; Updated June 4, 2016; December 8, 2018: NASBA National Registry of CPE Sponsors ID (if applicable, applies to self-study and nano-learning).

Documentation must be retained for not less than five years.

Updated November 21, 2014; December 9, 2017: Documentation for technical committee sessions must include a written certificate including the following:

1. the nature of the activity (e.g., topic or specific new competency acquired), the items discussed, and the source/material considered;
2. the dates of the learning activity; and
3. the number of CPE credits atributed to the learning activity.

Effective December 9, 2017: Acceptable evidence for credit of publications is a copy of the publication that names the licensee as author or contributor, a statement from the licensee supporting the number of CPE credits claimed, and the name and contact information of the independent reviewer(s) or publisher.

Prior to November 21, 2014: For courses taken for academic credit in universities and colleges, evidence of satisfactory completion of the course and receipt of academic credit will be sufficient (i.e., transcripts); for noncredit courses, a statement of the hours of attendance, signed by the instructor, must be obtained by the individual.

The renewal or reporting deadline.

Effective July 13, 2012 (Updated June 4, 2016): Active licensees will be required to affirm their compliance with the basic requirement upon annual renewal. This affirmation will be for the three calendar years immediately preceding the renewal year.

• Note: May 30, 2012:CeriFi has confirmed with the MT Board that the three-year rolling period ending in 2012 (which would have ended June 30, 2012) will now encompass the dates between July 1, 2009 through December 31, 2012.

Prior to July 13, 2012: July 31.

→ Get monthly reminders before this deadline

What happens if the requirement is not met.

Noncompliance with the CPE requirements may result in late fee penalties and/or the Board's refusal to renew the license.

Verification:

Effective June 4, 2016:

1. Licensees notified that they have been randomly selected for an audit of their basic CPE requirement must submit all courses and appropriate documentation using the NASBA CPE tracking system and comply with the deadline for submitting documentation.
2. Only documentation as outlined in ARM 24.201.2124, in support of the basic CPE requirement, shall be submitted.

Effective November 21, 2014 - June 3, 2016:

1. Permit holders notified that they have been randomly selected for an audit of their basic CPE requirement must comply with the deadline for submitting documentation.
2. Only documentation as outlined in ARM 24.201.2124 (refer to "Reporting Method" above), in support of the basic CPE requirement, shall be submitted. Individuals may submit documentation of up to 150 if they so choose, to make sure the basic requirement is substantiated in the audit.

Effective July 13, 2012 - November 20, 2014:

1. The board will verify compliance with the basic CPE requirement by annual random audit of up to 50 percent of licensees.
2. Licensees notified that they have been randomly selected for an audit must comply with the deadline for submitting documentation.
3. Only documentation as outlined in ARM 24.201.2124 (refer to "Reporting Method" above), in support of the basic CPE requirement, shall be submitted. Individuals may submit documentation of up to 150 if they so choose, to make sure the basic requirement is substantiated in the audit.
4. The Board will review all cases in which compliance with the basic CPE requirement could not be verified by the staff.

Prior to July 13, 2012:

1. The board will verify continuing education information submitted by individuals by random audit.
2. If an application is not approved, the individual will be so notified in writing and may be granted a period of time by the board, in which to correct the deficiencies noted. The board will audit the CPE reporting form and supporting documentation to verify completion of the basic requirement.
3. If specific CPE is recommended as a result of the profession monitoring program reviews, the board will audit the CPE supporting documentation to verify completion of the appropriate subject matter and number of credit hours.
4. Out-of-state applicants licensed in another jurisdiction applying for a permit to practice in this state must submit a CPE reporting form documenting compliance with CPE requirements with their application. The board may verify or audit CPE submitted by out-of-state applicants on a case-by-case basis.
5. Applicants seeking reactivation or reinstatement of a permit to practice must submit a CPE reporting form and supporting documentation to be verified by the board. The CPE requirements may be met in the three years immediately preceding the application for reactivation or reinstatement.

Reduced or prorated requirements for a first renewal.

Effective July 13, 2012; Updated November 21, 2014; June 4, 2016; December 9, 2017: Applicants for a license must meet the basic requirement of CPE by December 31 of the third year following the year of the initial issuance of the Montana license (example: If an individual received their license in 2017, they must meet the basic CPE requirement by December 31, 2020).

Effective May 1, 2020: New licensees must meet the basic requirement of CPE by December 31 of the third year following the year of the initial issuance of the Montana license. CPE completed during the initial licensing year does not accrue toward the first reporting period (example: If an individual received their initial license in 2020, they must meet the basic CPE requirement between January 1, 2021 and December 31, 2023).

Prior to July 13, 2012: The first full CPE period for new licensees ends three years from the June 30 following an individual's initial application for permit to practice. Credits earned between the date of initial licensure and the immediately following June 30 cannot be applied towards the CPE requirement of the licensee's first full CPE period. For purposes of determining date of initial licensure in Montana, a licensee who is licensed on account of holding a license in another state shall use the date of initial licensure in that state.

Rules for professionals licensed elsewhere.

Practice Privilege:

Effective November 21, 2014: Any individual who qualifies for the practice privilege in this state must meet the CPE requirements applicable in the jurisdiction of his or her principal state.

Prior to November 21, 2014: Applicants for a permit to practice who are transferring into Montana via licensure in another jurisdiction, who have been licensed for less than three years, are granted the same time period in which to meet Montana's basic CPE requirement, based on their original licensure date in the other jurisdiction.

Out-of-State Applicants Seeking a Montana Permit to Practice:

Effective December 9, 2017: A nonresident Montana licensee shall be determined to meet Montana CPE requirements by meeting the CPE requirements in the state where their principal place of business is located. If the nonresident licensee's principal place of business state has no CPE requirements for renewal, the nonresident licensee must comply with all CPE requirements for renewal of a license in Montana.

Effective November 21, 2014; Repealed June 4, 2016: An individual who receives a permit from this state by transfer of license, shall be required to comply with the basic requirement in Montana.

Effective July 13, 2012 - November 20, 2014: An individual, who holds a valid and unrevoked certified public accountant certificate or public accountant license issued by any jurisdiction, and who makes application under the appropriate provisions of the statutes for a certificate or license in this state, and who receives a certificate or license from this state, shall be required to comply with the basic requirement before being issued a permit to practice in this state.

Prior to November 21, 2014: Applicants for a permit to practice who are transferring into Montana via licensure in another jurisdiction, who have been licensed for more than three years, must submit proof of having met Montana's basic CPE requirement at the time of application.

Who may be excused from all or part of this requirement.

Extension or Hardship Exception:

Effective July 13, 2012; Updated November 21, 2014; June 4, 2016; December 8, 2018: The board or its designee may grant, for a specific period of time, an extension in order to complete the basic CPE requirement, or grant a written hardship exception for reasons of individual hardship (i.e. health or military service). To request an extension or hardship exception, an individual must submit the appropriate form. The board or designee will evaluate the request on a case-by-case basis..

Reinstatement:

Effective October 29, 2010: An individual formerly the holder of a permit who wishes to apply for reinstatement of the permit must satisfy the provisions of ARM 24.201.2106 ("Basic Continuing Education Requirement") in the three years immediately preceding application for permit reinstatement. Supporting documentation verifying the completion of CPE must be submitted to the board with the petition for reinstatement.

Inactive to Active License - Restoration: Updated November 21, 2014, June 4, 2016, December 9, 2017:

1. A licensee who holds a license in good standing but is not currently practicing public accounting may place the license on inactive status by informing the board office, in writing, that an inactive status is desired. It is the sole responsibility of the inactive licensee to keep the board informed of current contact information during the period of time the license remains on inactive status.
2. An inactive licensee may not use the title CPA, CPA (inactive), or practice public accounting in the state while the license is on inactive status.
3. An inactive licensee is required to renew on an annual basis.
4. An inactive license may be restored to active status by applying for active status, paying the restoration fee, and providing documentation verifying compliance with the continuing education rules of the board under ARM 24.201.2106 ("Basic Continuing Education Requirement"), within the three years immediately preceding the application for restoration to active status.
5. Montana licensees who use their Montana license to avail themselves of practice privileges in other jurisdictions, may not place the Montana license on inactive status while using the practice privilege.

Retired Status: Updated November 21, 2014, June 4, 2016, December 9, 2017:

1. A licensee who is fully retired from active employment in the practice of public accounting may submit a retired status request to the board. if the licensee:
   1. holds a license in good standing; and
   2. is at least 60 years of age; or
   3. has held a license in good standing for at least 20 years from a substantially equivalent jurisdiction as determined by NASBA's national qualifications appraisal service or a successor organization.
2. An applicant for retired status must affirm:
   1. they understand the scope of limitations on what services they offer;
   2. agreement not to use their retired status in any way which could be misleading; and
   3. maintenance of professional competence, without a specific CPE requirement, when offering any of the permitted volunteer services.
3. A retired licensee is required to renew on an annual basis, but is exempt from CPE requirements. It is the sole responsibility of the retired licensee to keep the board informed of current contact information.
4. A retired licensee may:
   1. use the designation "CPA (Retired)" or "LPA (Retired)."; and
   2. provide the following, volunteer, uncompensated services:
      1. tax preparation services;
      2. government-sponsored business mentoring programs; and
      3. serve on the board of directors for a non-profit organization.
5. An individual on retired status may apply for their license to be restored to active status by complying with all current year renewal requirements, paying the restoration fee, and providing documentation of compliance with continuing education rules of the board within the three years immediately preceding the application for restoration to active status.
6. Montana licensees who use their Montana license to avail themselves of practice privileges in other jurisdictions may not place their Montana license on retired status.

Whether unused credits can apply to the next period.

Effective July 13, 2012: Not specified.

• Note: April 9, 2012:CeriFi has confirmed with the MT Board that there will no longer be any carry forward or carry back CPE.

Prior to July 13, 2012:Applicants who have already met the full basic requirement by the end of any June 30th reporting period may elect to have excess continuing education hours taken during the immediately preceding months of May and June apply to the subsequent reporting period.

Prior to July 13, 2012:Applicants who have not completed their full basic requirements by the end of any June 30th reporting period may elect to have qualified continuing education hours taken during the immediately following months of July and August apply to the previous reporting period.

• Persons who use the two-month carry-back provision shall file their reporting forms by July 31, listing the course(s) they are planning to attend or complete.
• If the course(s) listed are not completed, they must notify the board office in writing immediately, but not later than August 31.
  • Such notification(s) shall explain why the course(s) were not completed and provide a plan to meet the continuing education requirements.

→ CE Tracking calculates carryover for you

Rule changes the regulator has finalized, with effective dates.

Refer to the specific sections above for more details on any of the items noted below.

Effective December 8, 2018: The Board made minor verbiage changes to rules related to:

• Extension or Hardship Exceptions;
• Reporting Requirements; and
• Standards for CPE Reporting

Effective December 9, 2017: NASBA recently adopted new continuing professional education (CPE) standards. Because of this, the MT Board formed a task force and revised its CPE requirements to align with the new NASBA standards. Significant changes included:

• Adoption of 2 new NASBA delivery formats: "nano-learning" and "blended learning."
• Revised CPE calculations: Allow for .2 (as well as .5) increments for CPE once specific minimums are reached.
• Introduction of new "Technical Subjects" requirement: Beginning on January 1, 2018, licensees must earn 50% (or 60 hours) of CPE in each 3-year period in technical subjects.
• To go along with the new "Technical Subject" requirement noted above, the Board has revised its acceptable subject areas into "Technical subjects" and "Nontechnical subjects."
• The Board now allows CPE credit for "technical reviewers."
• Other wording and textual clarifications. Refer to the paragraphs above which are preceded by "December 9, 2017."

June 4, 2016 Update: The MT Board has made numerous minor updates and clarifications in CPE rule language, among them renaming "permit holders" to "licensees" and removing references to "QAS."

• Refer to paragraphs in the sections above which are preceded by June 4, 2016 for more details.

November 21, 2014 Update: The MT board has updated and rewritten many regulations, several of which are related to CPE. The changes are meant to streamline and simplify board rules. With regard to CPE, the amendments to the rules only clarify requirements, but add no additional burden to current licensees or new applicants.

• Refer to paragraphs in the sections above which are preceded by November 21, 2014 for more details.

Cycling Period:

Effective July 13, 2012: Beginning in 2012, the annual period ends on December 31. The three-year rolling period ending 2012 (which would have ended June 30th) will now encompass the dates between July 1, 2009 through December 31, 2012, as the 2012 CPE year was extended six months in order to accommodate the change from a fiscal year to a calendar year.

Breakdown of Specific Requirements:
Effective July 13, 2012: Holders of a Montana permit to practice are required to have 120 hours of continuing professional education (CPE) with a subset of two hours in ethics in any rolling three-year period.

Start Date:
Effective July 13, 2012: Beginning with the 2012 period, the rolling three-year period will be based on the calendar year. To make the change from fiscal year to calendar year, licensees will be able to count CPE obtained between July 1, 2011 and December 31, 2012, toward the 2012 year.

Reporting Method:
Effective July 13, 2012: Holders of a permit to practice are required to affirm their compliance with the basic CPE requirement as required by the Board, upon annual renewal. This affirmation will be for the three calendar years immediately preceding the renewal year.

Effective July 13, 2012: Reporting of actual courses/credits is not required, unless the CPE is dictated by the board as a result of the profession monitoring program, the individual is selected for a random CPE audit as outlined in ARM 24.201.2148 (refer to "Enforcement" section), or the individual must otherwise prove compliance for licensure purposes (i.e. renewing an expired license, reactivating a license, transfer of license).

Effective July 13, 2012: Participants in group or self-study programs must document obtain documentation of their participation including NASBA Registry ID or NASBA QAS Sponsor ID (if applicable).

Reporting Date:
Effective July 13, 2012: Holders of a permit to practice will be required to affirm their compliance with the basic requirement upon annual renewal. This affirmation will be for the three calendar years immediately preceding the renewal year.

• Note: May 30, 2012:CeriFi has confirmed with the MT Board that annual CPE reporting will be eliminated.

Requirements for New Licensees:
Effective July 13, 2012: Applicants for a permit to practice who have never been licensed in any jurisdiction must meet the basic requirement of CPE by December 31 of the third year following the year of the initial issuance of the Montana permit (example: If an individual received their permit to practice in 2010, they must meet the basic CPE requirement by December 31, 2013).

• Applicants for a permit to practice who are transferring into Montana via licensure in another jurisdiction, who have been licensed for less than three years, are granted the same time period in which to meet Montana's basic CPE requirement, based on their original licensure date in the other jurisdiction.
• Applicants for a permit to practice who are transferring into Montana via licensure in another jurisdiction, who have been licensed for more than three years, must submit proof of having met Montana's basic CPE requirement at the time of application.

Requirements for Non-residents:
Effective July 13, 2012: Out-of-State Applicants Seeking a Montana Permit to Pratice - Continuing Education Requirement: An individual, who holds a valid and unrevoked certified public accountant certificate or public accountant license issued by any jurisdiction, and who makes application under the appropriate provisions of the statutes for a certificate or license in this state, and who receives a certificate or license from this state, shall be required to comply with the basic requirement before being issued a permit to practice in this state.

Exemptions:
Effective July 13, 2012: To request an extension or exception, an individual must submit the appropriate form and fees. The board will review requests on a case-by-case basis.

Carryover Credit:
Effective July 13, 2012: Not specified.

• Note: April 9, 2012:CeriFi has confirmed with the MT Board that there will no longer be any carry forward or carry back CPE.

Enforcement:
Effective July 13, 2012: Verification:

1. The board will verify compliance with the basic CPE requirement by annual random audit of up to 50 percent of licensees.
2. Licensees notified that they have been randomly selected for an audit must comply with the deadline for submitting documentation.
3. Only documentation as outlined in ARM 24.201.2124 (refer to "Reporting Method" above), in support of the basic CPE requirement, shall be submitted. Individuals may submit documentation of up to 150 if they so choose, to make sure the basic requirement is substantiated in the audit.
4. The Board will review all cases in which compliance with the basic CPE requirement could not be verified by the staff.

Credit for Teaching and Repeat Credit:
Effective July 13, 2012: Lecturers, instructors, and speakers may claim continuing education credit for both preparation and presentation time to the extent the activities maintain or increase their professional competence and qualify for continuing education credit for participants.Credit may be claimed for actual preparation time up to two times the class credit hours once in any rolling three-year period. The maximum credit for such preparation and teaching shall not exceed 50% (or 60 hours) of the basic requirement in any rolling three-year period.

Credit for Writing:
Effective July 13, 2012: Credit may be claimed for published articles and books provided they contribute to the professional competence of the individual. Credit for the preparation of such publications may be claimed on a self-declaration basis, not to exceed 25 percent (or 30 hours) of the basic requirement, unless exceptional circumstances justify greater credit. The final amount of credit awarded will be determined by the board on a case-by-case basis.

Credit for Self-Study Education:
Effective July 13, 2012: Formal self-study programs shall receive continuing education credit equal to the amount granted by the sponsor, if the sponsor is a NASBA Registry or NASBA QAS sponsor. These programs are calculated on a 50-minute hour.

Other Special Rules:
Effective July 13, 2012: Continuing education credit may be claimed for serving as a report reviewer under the board's profession monitoring program established in the Board regulations, or under other structured report review programs to be approved on a case-by-case basis by the board. Once approved, one hour of credit shall be granted for every hour spent reviewing reports. The maximum credit for such reviews shall be no more than 16 hours in any given calendar year.

Certificates of Attendance:
Effective July 13, 2012: The certificate of attendance must include the NASBA Registry ID or NASBA QAS Sponsor ID (if applicable).

Other Special Rules:
Related to the Board's profession monitoring program:

• Effective October 29, 2010: One hour of credit shall be granted for every hour spent reviewing reports. (Prior to October 29, 2010: One hour of credit shall be granted for every two hours spent reviewing reports.)
• Effective October 29, 2010: The maximum credit for such reviews shall be no more than 16 hours in any given fiscal year reporting period. (Prior to October 29, 2010: The maximum credit for such reviews shall be no more than eight (8) hours in any given fiscal year reporting period.)

Credit for Self-Study Education:
Effective October 29, 2010: Interactive self-study programs shall receive continuing education credit equal to the average completion time, if the sponsor is recognized and approved by NASBA's CPE quality assurance service (referred to as a NASBA QAS sponsor) or NASBA's national registry of CPE sponsors (referred to as a NASBA registry sponsor).

• An interactive self-study program is designed to use interactive learning methodologies that simulate a classroom learning process that provides significant ongoing, interactive feedback to the participant regarding the participant's learning progress.
• All other interactive and noninteractive self-study programs receive continuing education credit equal to one-half of the average completion time.
• Individuals claiming credit for such formal self-study courses are required to obtain evidence of satisfactory completion of the course from the program sponsor.

Breakdown of Specific Requirements:
For periods ending June 30, 2005 and earlier: At least 24 hours of the 120 hours of acceptable continuing education credit must consist of subjects related to the reporting on financial statements (as defined in ARM 8.54.204).

• NOTE: CeriFi has confirmed that this rule no longer applies to periods ending June 30, 2006 and after.