New Inactive and Emeritus CPA License Status Policy Effective July 1, 2026

VBOA Policy

TITLE: Inactive and Emeritus License Status EFFECTIVE DATE: July 1, 2026

Code of Virginia § 54.1-4402(D), § 54.1-4409.1, and VBOA regulation 18VAC5- 22-90(C)

The purpose of this policy is to outline the requirements of two license status

classifications: Inactive status and Emeritus status. Each license status must be granted and used in accordance with the terms specified below. Both the Inactive and Emeritus statuses must be proactively applied for and be approved in writing by the board. These license statuses are not automatically applied to a licensee, nor can they be unilaterally selected by a licensee. Unless a licensee has received written approval for Inactive or Emeritus status, the licensee must comply with all Continuing Professional Education (CPE) requirements as outlined in 18VAC5-22-90. Any Virginia licensed CPA who is approved for Inactive or Emeritus status still holds a CPA license. Therefore, licensees who hold either of these statuses are still subject to the Code of Virginia § 54.1-4413.3 Standards of conduct and practice, which requires individuals who provide volunteer services under these statuses to continue to meet the AICPA Code of Professional Practice standards and ensure they maintain professional knowledge and skills in performing any of their responsibilities. Inactive Status A person who holds a Virginia CPA license under the Inactive status is (i) not actively employed or has transitioned to a job outside of the financial field that does not require the substantial use of accounting, financial, tax, or other related skills, as determined by the board; and (ii) not providing services to the public or providing services to or on behalf of an employer, as defined in § 54.1-4400. This includes providing financial services in any compensated or volunteer role. Such individuals are exempt from all CPE requirements and may use the CPA title, provided that the designation "CPA (Inactive)" appears in all instances of use. To be considered for Inactive status, the applicant must satisfy the qualifications outlined above, in addition to the following criteria:

• Licensee holds a current Active license in good standing.
• Licensee has held an Active Virginia license for at least five years.
• Licensee is not the subject of a pending CPE audit or disciplinary action by any jurisdiction. Page 1 of 3 POLICY STATEMENT: AUTHORITY

Emeritus Status A person who holds a Virginia CPA license under the Emeritus status is (i) retired from employment; and (ii) not providing services to the public or providing services to or on behalf of an employer, as defined in § 54.1-4400. Such individuals are exempt from all CPE requirements and may use the CPA title, provided that the designation "CPA (Emeritus)" appears in all instances of use. To be considered for Emeritus status, the applicant must satisfy the qualifications outlined above, in addition to the following criteria:

• Licensee holds a current Active or Inactive license in good standing.

• Licensee is not the subject of a pending CPE audit or disciplinary action by any
  jurisdiction.

• Licensee has been actively licensed for:

• At least 30 years; or

• At least 15 years and has reached at least 60 years of age.
  Procedure for the Approval/Denial/Appeal of Inactive or Emeritus status

1. Application is submitted by the applicant to the VBOA.

2. Upon review by the Executive Director or designee, the application is either approved
   or denied.

3. If approved, the applicant is informed in writing and the license status is
   changed.

4. If denied, the applicant is informed in writing.

5. If the application is denied, the applicant may request an appeal and provide
   additional documentation to support the appeal.

6. Upon review by the VBOA Vice Chair or designee, the appeal is either approved or
   denied and the applicant is informed in writing. No further appeals are available. Return to Active Status Prior to accepting any position that exceeds the limitations and requirements of Inactive or Emeritus status, including providing any financial related services to the public or to or on behalf of an employer, a person must apply to return to Active status and complete 120 hours of CPE, including a current two-hour, VBOA-approved ethics course, prior to providing services. APPROVAL AND REVIEW: This VBOA policy was approved on December 4, 2025, and is effective July 1, 2026.

SUPPRESSION: This VBOA policy replaces Board Policy #9 that was effective on March 5, 2020. VBOA CHAIR AT

LAST REVIEW: Nadia Rogers, CPA, Chair Page 2 of 3

VBOA MEMBERS AT Nadia A. Rogers, CPA, Chair

Dale G. Mullen, Vice Chair LAST REVIEW: Guy A. Davis, CPA Anne B. Hagen, CPA Wendy P. Lewis, CPA, Christine Williamson, CPA Angela Rudolph-Wiseman, CPA

EXECUTIVE DIRECTOR: Nancy J. Glynn, CPA

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