Enforcement Law and Rule Updates for 2024-2025
Rule Amendments:
California
Rule Number: The CBA proposes amendments to CCR section 98 to update the 10th Edition, 2019 of the Disciplinary Guidelines and Model Orders to 11th Edition 2023.
Status: Pending; Proposed June 2025
New language is added to allow a licensee to surrender a license while on probation. New evidence is allowed as supporting documents licensees can include in their Petition for Reduction of Penalty, as it relates to a financial penalty. Additionally, the proposed amendment to the California Accountancy Act section adds the Ethics Continuing Education (CE) and National Association of State Boards of Accountancy’s (NASBA) Center for the Public’s Trust (CPT) Ethical Leadership Training to the “If warranted” section of the Conditions of Probation. The basis for the change is to provide the CBA the option of imposing one or both trainings – the Ethics CE course and/or the NASBA CPT Ethical Leadership training – as a condition of probation to rehabilitate the licensee.
Florida
Rule Number: 61H1-36.004
Status: Enacted – Effective April 16, 2025
This rule addresses disciplinary guidelines and offers a range of penalties, including considerations for aggravating and mitigating circumstances. The rule includes a chart for new disciplinary guidelines and enforcement rules.
New Hampshire
Rule Number: Ac 402 Revocation, suspension, and other sanctions
Status: Pending; Proposed October 2024
In regards to professional misconduct, this rule makes amendments to the board’s disciplinary process. It deletes the sections on revocation, suspensions, and primary sanctions, and adds a procedure for imposition of sanctions. It deletes the Voluntary Surrender by Licensees section. This rule readopts Rule Ac 402.06 with an amendment regarding Administrative Fines to include the Office of Professional Licensure and Certification. This rule repeals section Ac 402.07 which pertains to assessing and collecting fines.
Washington
Rule Number: Board Policy
Status: Pending but planned to be effective 07/19/2025
This rule makes amendments to the investigative and disciplinary process as well as to the publication and disclosure of disciplinary actions.
Statute Changes:
Alaska
HB 121
Status: Pending; Passed both houses May 19, 2025
Summary: While you may have heard of this bill because it removes the requirement for 150 semester hours of education for CPAs and it simplifies practice privileges for out-of-state accountants, this bill also revises disciplinary procedures, permitting revocation or suspension of a firm’s permit due to violations by an owner and allowing reinstatement of revoked licenses.
Hawaii
SB 800
Status: Pending
Summary: This bill requires licensed professionals in Hawaii to report any pending legal claims, actions, or administrative complaints against them to their respective licensing boards within thirty (30) days of receiving such notifications. The licensing boards are then mandated to review these reports and conduct further inquiries as necessary.
Mississippi
SB 2786
Status: Failed
Summary: This bill was titled “An Act To Enact The Ending Agency Overreach Act” which attempted to direct a court to interpret a statute or agency rule or regulation de novo in response to the Supreme Court case Loper v. Bright Enterprises a landmark case in Administrative Law which overturned Chevron deference. This bill also provided that no civil penalty may be awarded in an action brought by or on behalf of an administrative agency of the state against any person or legal entity for conduct that would also be the subject of a suit at common law in which the defendant would be entitled to trial by jury, except after a trial by jury before a circuit, county, or chancery court. This bill also attempted to authorize a person or entity to contest the validity of an agency rule up to one year after the date the person or entity bringing the action is injured by final agency action.
Missouri
HB 766
Status: Failed
Summary: This bill aimed to repeal provisions relating to suspension of professional licenses for failure to pay state taxes or file state tax returns.
Nevada
AB 264
Status: Failed
Summary: This bill aimed to establish procedures by which an applicant for a professional or occupational license may obtain judicial review of the decision of a licensing agency denying the application of the applicant on the basis of the moral character or criminal history of the applicant. This bill also aimed to establish procedures for judicial review of professional or occupational license denials in Nevada when based on an applicant’s moral character or criminal history. It would have required licensing agencies to provide written notice of denial within 10 days, explaining the decision and the applicant’s right to appeal. It also would have allowed applicants to petition the district court within 30 days, and the licensing agency must prove by clear and convincing evidence that issuing the license would pose a direct, substantial, and unmitigatable risk to public health or safety. This bill provided that if the agency failed to meet this burden, the court must order the agency to grant the license. The bill aimed to ensure transparency and fairness in licensing decisions while allowing individuals to challenge denials effectively.
Pennsylvania
S 719
Status: Pending, Passed both houses June 26, 2025
Summary: While this bill received attention for changes to substantial equivalency, it also covers grounds for discipline, for reinstatement, and for unlawful acts.
Texas
HB 794
Status: Failed
Summary: This bill aimed to create limitations on the enforcement of certain occupational regulations by requiring each licensing authority to conduct a comprehensive review of each regulation by September 1, 2026, specifying the regulation’s purpose and reasons for its necessity. If a regulation violates Section 2.002, the authority can repeal or modify it, or recommend the legislature’s repeal. A person can also bring an injunction against the enforcement of an occupational regulation in a district court.
Utah
HB 474
Status: Enacted – Effective May 7, 2025
Summary: Regulatory Oversight Amendments including the provision of circumstances when the Office of Professional Licensure Review shall document and justify the office’s basis for the office’s decision resulting from the review. The amendment also allows an individual to petition the office to repeal or modify any occupational regulation within the office’s jurisdiction; creates a process for an individual to appeal the office’s decision after a request to repeal or modify; and provides a limit on the cost of implementing an agency generated rule.
Utah
SB 15
Status: Enacted – Effective July 1, 2026.
Summary: In addition to amending the licensing requirements for CPAs and modifying mobility provisions, this bill empowers the Division of Professional Licensing to issue citations and impose fines for unlawful conduct related to CPAs, thereby strengthening regulatory oversight.