IMPLEMENTATION OF NEW BACHELOR ONLY PATHWAY TO LICENSURE OPTIONS FOR CPA LICENSURE ON OR AFTER JANUARY 1, 2026, DUE TO PASSAGE OF SENATE BILL 797 (2025)
This FAQ section and other parts of the Board’s web site will be updated in early January with the exposed rules and where/how to comment.
WHEN: Apply any time using the regular licensure application on the Board’s web site. Oregon Board of Accountancy (OBOA) staff will automatically determine if any active applications toward initial licensure qualify under any of the pathway options available.
ISSUANCE TIMELINES:
1. Until December 31, 2025, only applications for initial licensure that qualify under the existing, 150 semester hours plus minimum one year of qualifying experience and passage of the CPA exam can be approved and issued by OBOA licensing staff.
2. THERE WILL BE A ONE-MONTH PAUSE (JANUARY 1-31, 2026) ON ISSUING ANY NEW CPA CREDENTIALS WHILE OBOA WORKS THROUGH A RULEMAKING PROCESS TO ALIGN ITS RULES WITH THE STATUTORY CHANGES TRIGGERED BY THE LICENSURE PATHWAY BILL, SENATE BILL 797 (2025).
3. Any application for initial licensure pending with OBOA on or after January 1, 2026, will be automatically evaluated if it qualifies for any of the pathways toward CPA licensure available under Senate Bill 797.
4. Regardless of licensure pathway, unless an application for initial CPA licensure was approved and issued on or before December 31, 2025, new initial individual CPA licenses cannot be issued until pathway implementation rules are finalized (estimated February 1, 2026).
RULES IMPLEMENTING NEW LICENSURE PATHWAY: On Dec. 1, 2025, the Board of Accountancy voted to expose pathway implementation rules on January 1, 2026 (the earliest date permitted by Senate Bill 797). Final OBOA consideration will take place during a regular Board meeting on January 29, 2026, including a Rulemaking Hearing that starts at 9:00 a.m. to hear oral comments, and review any written comments received.
THERE ARE THREE (3) CPA LICENSURE PATHWAYS AVAILABLE IN OREGON AS OF JANUARY 1, 2026:
1. 150-SEMESTER HOUR PATHWAY:
This is the traditional pathway requiring a degree and 150 semester hours, plus one year of supervised experience and passage of the CPA exam. This is the old pathway that REMAINS IN PLACE for three reasons:
- Keeping this pathway in place is helpful to ensure Oregon CPAs retain full mobility privileges allowing them to practice in all other U.S. jurisdictions.
- those that come to accounting late and have degrees in other disciplines still benefit from this pathway.
- We have accountants who want to pursue a Master’s-level education who then benefit from the shorter experience requirement.
2. MASTER’S DEGREE PATHWAY.
This is essentially the same pathway as the 150-hour pathway, but removes the 150-semester hour specificity to allow our licensing sytem to adopt to evolution in the higher education system that may award a Master’s degree without meeting a 150-semester hour threshold.
3. BACHELOR’S DEGREE PATHWAY:
This is the much talked about new pathway that requires a Bachelor’s degree (NOT 120 semester hours specifically, although that is typical for most Bachelor’s degree programs) plus longer supervised experience (2 years / 24 months / 4000 hours minimum) and passage of the CPA exam.
NOTE: REGARDLESS OF PATHWAY, ALL SPECIFIC EDUCATION REQUIREMENTS FOR ACCOUNTING-SPECIFIC AND ACCOUNTING-RELATED COURSES CONTINUE TO APPLY - SEE BELOW.
DO THE REQUIREMENTS TO SIT FOR THE CPA EXAM AS AN OREGON CANDIDATE CHANGE ON JANUARY 1, 2026, WHEN SENATE BILL 797 TAKES EFFECT?
YES.
In alignment with the changes to the new pathway (option 3 above, which removed the 120-semester hour specific criterion and simply requires a bachelor’s degree) the 120-semester specific requirement is being removed for Oregon candidates to sit for the CPA exam effective January 1, 2026, and replaced with a bachelor’s degree requirement. The accounting education requirements for accounting-specific and accounting-related education continue to apply unchanged to Oregon applicants to sit for the CPA exam.
SUPERVISED EXPERIENCE: Oregon remains a jurisdiction that embraces competency-based supervision requirements toward licensure. This does not change under Senate Bill 797 (2025). Effectively that means that the exact same requirements of who qualifies as a supervisor toward licensure, and what the competencies toward licensure are, are not proposed to change in any way, except solely with respect to the minimum length of supervision depending on the pathway chosen. (Bachelor’s only pathway – minimum of two (2) years; Master’s degree or 150 semester hour pathway - minimum of one year.)
Can qualifying supervision toward licensure obtained prior to January 1, 2026, be counted toward the new Bachelor’s-only pathway toward CPA licensure pathway?
YES.
Can qualifying supervision toward licensure be obtained if I am combining different employers and different experience pathways (audit/tax/private industry)?
YES.
Note: Please be sure to use separate forms if you have different supervisors sign off on different portions of your supervised experience. This also means only using the supervision form for the attest pathway only for attest experience and only using the supervision forms for tax and private industry for experience signoffs in those areas.
ARE THE ACCOUNTING SPECIFIC EDUCATION REQUIREMENTS (a.k.a. BUCKETS) CHANGING WITH THE IMPLEMENTATION OF THE NEW PATHWAYS?
NO.
1. Rules to be exposed will propose no changes to our education requirement buckets regardless of the pathway under which an applicant for initial licensure qualifies.
2. OBOA is proposing to retain the same approach to the accounting-specific bucket (24 sememster hours or 36 quarter hours) of upper-division accounting courses while allowing up to 4 sem. hours of accounting upper division internship credits). OBOA is also proposing no changes to the 24 sememster hours or 36 quarter hours of accounting-related coursework.
DO ANY OF THE PATHWAYS TOWARD CPA LICENSURE IN OREGON AVAILABLE ON OR AFTER JANUARY 1, 2026, ELIMINATE A DEGREE REQUIREMENT?
NO.
Either a Bachelor’s degree or Master’s degree is still required for CPA licensure.
DO ANY OF THESE CHANGES IMPACT APPLICANTS FOR OREGON LICENSURE BY RECIPROCITY?
YES.
Since Board rules and statutes will temporarily diverge between January 1 and January 31, 2026, also with respect to reciprocity applications for licensure, OBOA staff will also need to suspend issuance of reciprocity licenses during that time. Any applications for reciprocity licensure pending on January 1, 2026, or received in January 2026, will be automatically processed in February 2026 as soon as the new rules are finalized.