CPA vs Accountant: What the License Actually Changes
Every CPA is an accountant; most accountants are not CPAs. What the state license adds, what it does not, and how to check one.

Every CPA is an accountant. Most accountants are not CPAs. The Bureau of Labor Statistics counted 1,595,200 people working as accountants and auditors in its May 2025 data, while NASBA counted 650,667 actively licensed CPAs as of August 27, 2026. The license is granted by a state board of accountancy, not by a professional body or by the federal government, and what it uniquely buys is the right to issue audits, reviews and other attest reports through a licensed firm. It does not reserve tax return preparation, IRS representation, bookkeeping or advisory work to its holders.
The short version: hire a CPA when a lender, investor, regulator or buyer needs a signed attest report, or when you want a credential a state board can revoke standing behind the advice. For everything else, the license is one input into the decision rather than the decision.
If what you are working out is the split between recording the numbers and interpreting them, that is a different question: bookkeeper vs accountant covers the two jobs. This page is about the credential.
CPA vs accountant at a glance
| Point of comparison | Accountant without a CPA license | CPA |
|---|---|---|
| License | None required to use the title or do the work. | A state license, granted by a state board of accountancy, the District of Columbia or a US territory. |
| Who regulates it | No regulator of the title. | The issuing state board, with ethics rules, continuing education and the power to discipline or revoke. |
| What only they may do | Nothing is reserved by the title. | Audits, reviews and other attest reports, issued through a licensed CPA firm. |
| Typical work | Bookkeeping oversight, management accounts, the close, tax returns, payroll, advisory. | The same, plus attest work. |
| How they charge | Per return, hourly, or a monthly fee. | Per return, hourly, or a monthly fee. In the 2019 to 2020 NSA survey, audit of financial statements averaged $163.69 an hour and financial statement presentation $163.85. |
The row that does the work is “what only they may do”. Everything else on that table describes how the two tend to be used. Attest is the line the statutes actually draw.
The two counts, and what they do and do not prove
These are the numbers behind “most accountants are not CPAs”, and they need their caveats stated or they mislead.
| Count | Figure | As of | What it measures |
|---|---|---|---|
| Accountants and auditors, employment | 1,595,200 | May 2025 | A BLS occupation, including self-employed workers |
| Accountants and auditors, survey employment | 1,449,500 | May 2025 | The same occupation in the OEWS survey, which excludes the self-employed |
| Actively licensed CPAs | 650,667 | August 27, 2026 | A credential, counted from state board records |
Two cautions. First, NASBA’s figure comes from the Accountancy Licensee Database, which its own page describes as aggregated from 53 of the 55 CPA licensing jurisdictions and which “does not include data from Hawaii or New Mexico and is based on license status data from the various boards that equate to an ‘active’ license.” Treat it as about 650,000 rather than an exact census. Second, BLS measures an occupation and NASBA measures a credential, and the two populations are not cleanly nested: a licensed CPA working as a chief financial officer or a professor is not counted in the BLS occupation at all. The two figures support the statement that CPAs are a minority of working accountants. They do not support subtracting one from the other.
BLS does not survey CPAs as a group, which is why no honest article can tell you “the median CPA earns X” from BLS data. The May 2025 median for accountants and auditors is $83,680 a year, or $40.23 an hour, across a much larger and less credentialed population, and it is a wage rather than a billing rate in any case.
What licensure requires
The IRS summarizes the requirements: CPAs are “licensed by state boards of accountancy, the District of Columbia, and U.S. territories” and “must pass the Uniform CPA Examination, complete college/university accounting study, meet experience and good character requirements, comply with ethical standards, and complete specified continuing education to maintain licensure.”
The exam is four sections of four hours each under the Core plus Discipline model: three Core sections, Auditing and Attestation, Financial Accounting and Reporting, and Taxation and Regulation, plus one Discipline section chosen from Business Analysis and Reporting, Information Systems and Control, and Tax Compliance and Planning. The minimum passing score is 75. The AICPA develops the exam. NASBA states that it “does not develop the content of the CPA Exam, nor is it responsible for scoring the Exam.” Neither body issues the license: the state board does.
The 2025 change to how someone qualifies
On May 14, 2025 the boards of the AICPA and NASBA approved adding a pathway to the Uniform Accountancy Act, the model law the states draw on: “a baccalaureate degree, including an accounting concentration, plus two (2) years of experience, and passage of the Uniform CPA Examination.” That is 120 semester hours plus two years, instead of 150 hours plus one year.
The 150-hour route was not abolished. The model law now sets out three pathways, which NASBA states as:
- Graduate Degree Pathway: “Graduate degree in accounting + one (1) year of professional experience + passing the CPA Exam.”
- Traditional 150-Hour Pathway: “Bachelor’s degree in accounting + 30 additional semester credits (total 150 semester hours) + one (1) year of experience + passing the CPA Exam.”
- New 120-Hour Pathway: “Bachelor’s degree in accounting (120 semester hours) + two (2) years of professional experience + passing the CPA Exam.”
The same update shifts mobility, the ability to practice across state lines without a separate license, “from a state-based system to an individual-based system.”
A model law is not law. As the Journal of Accountancy put it, “individual states will need to formally enact legislation and/or adopt rules and regulations, depending on the jurisdiction, before candidates can pursue this path.” States have been enacting through 2025 and 2026 on their own timetables, with different effective dates, and published counts of how many have done so disagree with each other. The authoritative record is NASBA’s own pathways tracker, which shows the effective date and a summary for each jurisdiction and which was marked current as of July 21, 2026. Check it for the state you care about rather than trusting a number in an article, including this one.
None of this changes what a license already granted permits. It matters if you are choosing a career, hiring someone newly qualified, or wondering why a candidate has a license without the extra thirty credits behind it.
What only a CPA may do
Attest work. A compilation, a review and an audit are three different engagements at three different prices and three different levels of assurance: a compilation expresses none, a review expresses limited assurance, and an audit carries an opinion. All of them are the province of CPAs working in licensed CPA firms.
The mechanism is state statute rather than a federal rule. North Carolina’s G.S. 93-6 lets a person who is not a CPA practice, so long as that person “uses the term ‘accountant’ and only the term ‘accountant’” on reports, letters of transmittal, advice, stationery and documents. The reports themselves are covered by a dedicated section of the board’s rules for CPAs performing attest services. The authorization is also conditional on external inspection: the AICPA states that “almost every firm that performs accounting or auditing work is required to undergo a peer review,” and the requirement bites at state level, as in New York’s mandatory peer review and Washington’s WAC 4-30-130, which makes participation in a board-approved peer review program a condition of renewing a firm license for firms performing attest services.
The practical consequence for a buyer is simple. If the document you need says “review” or “audit” on it, the pool of people who can produce it is CPAs in licensed firms, and no amount of experience substitutes. If it says “compilation”, the same restriction applies to the report even though no assurance is expressed.
What a CPA does not exclusively do
Preparing and signing tax returns. There is no federal credential requirement to prepare returns for payment. Any holder of a preparer tax identification number may do it. As of September 1, 2026 the IRS counted 886,338 PTIN holders, of whom 209,076 were CPAs. That is roughly one paid preparer in four holding the credential, which is worth knowing before treating the letters as the baseline for tax work rather than as one fact about the person.
Representing you before the IRS. The IRS grants unlimited representation rights to “enrolled agents, certified public accountants, and attorneys,” who may represent a taxpayer on any matter, including audits, payment and collection issues and appeals, whether or not they prepared the return. An enrolled agent is licensed federally by the IRS after passing a three-part examination covering individual and business returns, or through experience as a former IRS employee, and must complete 72 hours of continuing education every three years under Treasury Circular 230. For representation, an EA and a CPA carry identical authority, and the IRS counted 71,966 enrolled agents among PTIN holders on September 1, 2026. Paying a premium for a CPA purely to have someone who can represent you buys nothing an enrolled agent does not already have.
Bookkeeping, payroll, management reporting, forecasting and CFO-level work. None of it is attest work and none of it requires a license of any kind. If what you need is someone to own forecasting, margin analysis and the monthly reporting pack, that is fractional CFO work, and what matters there is operating experience rather than a license.
Limited representation exists as a middle tier: participants in the IRS Annual Filing Season Program, who earn a Record of Completion through required continuing education, may represent clients whose returns they prepared and signed, and only before revenue agents, customer service representatives and similar IRS employees. PTIN holders with no credential at all have had no representation authority since January 1, 2016.
When a lender or the SBA asks for CPA-prepared statements
This is where the license stops being a preference and becomes a requirement, and the SBA’s own Standard Operating Procedure is the clearest published example.
Under SOP 50 10 8, effective June 1, 2025, the CAPLines requirement reads: lenders must “obtain Borrower prepared financial statements and tax returns if the CAPLine amount is $1,000,000 or less and compiled, reviewed, or audited financial statements and tax returns if the CAPLine amount is over $1,000,000, consistent with lender’s policies governing its similarly-sized, non-SBA guaranteed commercial lines of credit.” A compiled, reviewed or audited statement means a CPA firm, so $1,000,000 is a real threshold at which the credential becomes unavoidable on that product.
On change of ownership, the same SOP allows that where a division or segment of an existing business is acquired, “the SBA Lender may use alternative forms of third-party verification such as third-party CPA-prepared or reviewed financial statements, sales tax payment records, transient occupancy tax, credit reporting services, etc., to verify the seller’s financial data.” That is permissive rather than mandatory, and it is worth reading carefully before assuming a CPA engagement is required.
SOP 50 10 8.1 takes effect October 1, 2026 and adds a diligence requirement worth knowing about if you are buying or expanding a business. For “Business Expansion and Initial Acquisition transactions where the Purchase Price as defined in Paragraph A.1 is equal to or greater than $3 million, the Lender must also obtain a Quality of Earnings (QoE) in addition to the required Business Valuation,” with the threshold “determined before the application of buyer equity, seller debt, or other financing sources,” and with owner buyout, ESOP and cooperative transactions excluded. The SOP defines a QoE as “an independent financial due diligence report that examines the reliability, sustainability, and accuracy of a business’s historical and projected earnings” that “must be performed by an independent qualified financial professional.”
Note the exact wording there: independent qualified financial professional, not CPA. The SOP does not restrict quality of earnings work to license holders, and anyone telling you the SBA requires a CPA for it is adding a word the document does not contain.
Outside SBA lending, the pattern is the same: a bank covenant, an investor agreement, a franchise agreement, a bonding company or a state regulator can each require reviewed or audited statements, and each of those requirements is in a document you can read. Ask which level of assurance is being demanded before commissioning anything, because a compilation, a review and an audit are separately scoped engagements and a quote for one tells you nothing about the price of another.
How to verify a license
A claimed credential is worth exactly as much as the check you run on it, and the checks are free.
- The state board that issued it is the authority. Boards publish licensee lookups, and the board is also where complaints and disciplinary history live.
- NASBA runs a multi-state lookup at cpaverify.org, which searches the Accountancy Licensee Database. It is convenient, and it carries the same coverage limit as the count above: 53 of the 55 licensing jurisdictions, with Hawaii and New Mexico absent. A person not found there is not necessarily unlicensed. Go to the board.
- Ask for the license number and the issuing jurisdiction in writing. A licensee will supply both without hesitation, and both are what the lookups take as input.
- For tax work, check the preparer separately. Anyone paid to prepare your return must hold a PTIN and must sign the return. The IRS publishes a directory of preparers holding credentials it recognizes. A preparer who takes a fee and leaves the signature block empty is the pattern the IRS warns about under the name ghost preparer.
- Check the firm as well as the person if you are buying attest work. Attest reports are issued by licensed firms, and the firm’s license is separate from the individual’s: Washington’s rule, for example, makes peer review a condition of renewing the firm license.
How to find the right one
Decide first whether you are buying an attest report, a tax return, or an ongoing relationship, because the three are shopped differently. For an attest report, start from firms licensed to issue it in your state and ask about peer review. For a return, ask for a fixed fee against a named list of forms, and remember that an enrolled agent holds the same IRS representation authority as a CPA. For an ongoing relationship, the license tells you there is a board standing behind the person, and the interview tells you whether they understand your business. Our directory lists accounting and CPA firms by state and city.
Frequently Asked Questions
Is a CPA better than an accountant?
A CPA is an accountant who holds a state license, so the comparison is between one accountant and another. The license adds a regulator with the power to discipline, mandatory continuing education and ethics rules, and the exclusive right to issue audits, reviews and other attest reports through a licensed firm. For bookkeeping, management accounts, tax returns and advice, an unlicensed accountant faces no legal restriction, and the choice comes down to the individual.
Can someone call themselves an accountant without a CPA license?
Yes. The word describes work rather than a credential. What is restricted by state statute is the CPA title and its abbreviations: North Carolina makes it unlawful for a non-holder to use words or letters indicating admission to practice as a certified public accountant, while expressly permitting the same person to use the term “accountant” alone. Title rules are state law and differ, so your state’s board of accountancy is the authority on the wording where you are.
Do I need a CPA to file my business taxes?
No. Any holder of a preparer tax identification number may prepare and sign a federal return for payment, and of 886,338 PTIN holders as of September 1, 2026, 209,076 were CPAs. What matters more than the license is whether the person can represent you if the return is questioned, and enrolled agents, CPAs and attorneys all hold unlimited representation rights before the IRS.
How many CPAs are there in the United States?
NASBA counted 650,667 actively licensed CPAs as of August 27, 2026, drawn from the Accountancy Licensee Database. That database aggregates 53 of the 55 CPA licensing jurisdictions and excludes Hawaii and New Mexico, so the true figure is somewhat higher and about 650,000 is the honest way to quote it.
Has the 150-hour rule for becoming a CPA been abolished?
No. On May 14, 2025 the AICPA and NASBA approved adding a pathway of a bachelor’s degree with an accounting concentration plus two years of experience and the CPA Exam, alongside the existing 150-hour and graduate degree routes. The model law now carries three pathways rather than one. Each state has to enact it separately, and NASBA’s pathways tracker, current as of July 21, 2026, is where to check the position in a given jurisdiction.
Sources
23 links
- NASBA: how many CPAs are there
- NASBA: CPA licensure pathways tracker
- NASBA: new CPA licensure pathways and CPA mobility, December 23, 2025
- NASBA: CPA Exam
- AICPA: AICPA and NASBA approve model legislation for new CPA licensure path, May 14, 2025
- Journal of Accountancy: AICPA, NASBA approve new CPA licensure path, May 14, 2025
- AICPA: CPA Exam toolkit
- AICPA: peer review
- IRS: understanding tax return preparer credentials and qualifications
- IRS: enrolled agent information
- IRS: federal tax return preparer statistics
- IRS Directory of Federal Tax Return Preparers with Credentials and Select Qualifications
- SBA: SOP 50 10, lender and development company loan programs
- SBA: SOP 50 10 8, technical updates effective June 1, 2025
- SBA: SOP 50 10 8.1, effective October 1, 2026
- North Carolina State Board of CPA Examiners: General Statute excerpts, G.S. 93-3 and 93-6
- North Carolina State Board of CPA Examiners: rules applicable to CPAs performing attest services
- New York State Education Department: mandatory peer review
- Washington Administrative Code 4-30-130: peer review as a condition of firm licensure
- BLS Occupational Outlook Handbook: accountants and auditors
- BLS: Occupational Employment and Wage Statistics, national table 1, May 2025
- National Society of Accountants: 2020 to 2021 Income and Fees of Accountants and Tax Preparers in Public Practice, full study
- NASBA CPAverify licensee lookup


