SB262

Regular Session

Relating to eligibility requirements to practice public accountancy.

ModeratePlan for compliance

Low Cost

Effective:2026-08-01

Enforcing Agencies

Texas State Board of Public Accountancy

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

Effective Date: August 1, 2026
Compliance Deadline: August 1, 2026 (Firms must be ready to process Track 2 candidates and apply new reciprocity standards immediately).
Agency Rulemaking: The Texas State Board of Public Accountancy (TSBPA) is required to define "accounting concentration" and specific experience criteria "as soon as practicable." Critical Advisory: A regulatory gray zone exists between now and the publication of these rules; do not finalize hiring criteria for the Class of 2026 until the Board defines the specific coursework required for the baccalaureate pathway.

Immediate Action Plan

Immediate: Audit current employment contracts and offer letters to identify "12-month licensure" clauses that will become unenforceable for Track 2 hires.
Q3 2025: Update credentialing checklists to include a "Date of Credit" verification step for all out-of-state lateral hires.
Q4 2025: Subscribe to TSBPA rulemaking updates to submit comments on the definition of "accounting concentration" to ensure it aligns with standard university curricula.
Spring 2026: Train supervising CPAs on the new 2-year mentorship requirements and documentation standards.

Operational Changes Required

Contracts

Employment Offer Letters: You must revise standard offer letters. Clauses requiring candidates to obtain licensure within 12 months are legally impossible for "Track 2" (Baccalaureate) hires, who require a statutory 24-month experience period. Create a specific "Track 2" template with a 24+ month licensure deadline.
Tuition Reimbursement Agreements: Review policies covering the "extra 30 hours" (Master’s degrees). Since this education is no longer a regulatory mandate for licensure, reclassify these payments as discretionary benefits. Strengthen clawback provisions for employees who accept tuition aid but switch to the experience-based track.

Hiring/Training

Dual-Track Supervision: HR Information Systems (HRIS) must be updated to track "experience hours" differently based on the employee's educational background.
Track 1: 150 Hours + 1 Year Experience.
Track 2: Baccalaureate + 2 Years Experience.
Reciprocity Vetting: Credentialing teams must stop assuming automatic reciprocity for out-of-state hires. You must now verify that the applicant met Texas requirements *at the specific time their exam credits were earned*.

Reporting & Record-Keeping

Experience Verification: Prepare for new TSBPA forms verifying the 2-year work requirement. The Board will require detailed attestation regarding the *nature* of the work, not just the duration.
Transcript Audits: Do not rely on degree titles. You must retain transcripts verifying that Track 2 applicants meet the forthcoming definition of "accounting concentration."

Fees & Costs

Internal Cost Shift: Expect a reduction in tuition reimbursement costs, offset by increased costs associated with longer mandatory supervision periods for Track 2 staff before they become billable as licensed CPAs.

Strategic Ambiguities & Considerations

The statute leaves critical definitions to TSBPA rulemaking. You must monitor the *Texas Register* for:

1. "Accounting Concentration": If the Board sets the credit hour requirement for this definition too high, it will effectively nullify the Baccalaureate pathway.
2. Qualitative Experience Standards: The Board may require that the 2-year experience track include specific types of work (e.g., audit vs. general tax) that differ from the 1-year track.
3. Equivalent Courses: The Board will define exactly which non-accounting courses count toward eligibility.

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Legislative Timeline

This bill's path through the Texas Legislature

TopicsOccupational Regulation Occupational Regulation--other Trades & Professions Public Accountancy, Texas State Board of Accounting & Accountants

Official Analysis

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BILL ANALYSIS

Senate Research Center	S.B. 262
	By: Perry
	Business & Commerce
	2/14/2025
	As Filed

AUTHOR'S / SPONSOR'S STATEMENT OF INTENT

S.B. 262 creates an additional pathway by proposing an alternative to licensure for Certified Public Accountant (CPA) candidates in Texas. The requirements of the alternate pathway would include the following:

A baccalaureate degree with an accounting concentration or the completion of the necessary accounting and business courses;
Two years of applicable work experience, as determined by board rule;
The passage of the Uniform CPA exam.

S.B. 262 is proposed to attract more candidates to the declining CPA Profession. S.B. 262 increases flexibility, upholds standards, and broadens the pipeline into the profession.

As proposed, S.B. 262 amends current law relating to eligibility requirements to practice public accountancy.

RULEMAKING AUTHORITY

Rulemaking authority is expressly granted to the Texas State Board of Public Accountancy in SECTION 5 of this bill.

SECTION BY SECTION ANALYSIS

SECTION 1. Amends Section 901.252, Occupations Code, as follows:

Sec. 901.252. ELIGIBILITY REQUIREMENTS. Requires a person, to be eligible to receive a certificate as a certified public accountant (certificate), to:

(1) makes no changes to this subdivision.

(2) complete:

(A) creates this paragraph from existing text and makes a conforming change; or

(B) a baccalaureate degree with an accounting concentration or equivalent courses that meet the education requirements established under Section 901.254 (Education Requirements), as determined by Texas State Board of Public Accountancy (TSBPA) rule; and

(3)-(5) makes no changes to these subdivisions.

SECTION 2. Amends Section 901.256, Occupations Code, by adding Subsection (a-1) to require a person, to be eligible to receive a certificate with a baccalaureate degree under Section 901.252(2)(B), to complete two years of experience as determined by TSBPA rule.

SECTION 3. Amends Section 901.258(a), Occupations Code, to authorize TSBPA to accept the completion of the uniform CPA examination given by the licensing authority of another state if certain conditions are met, including if the applicant met the requirements in effect in this state, as determined by TSBPA rule, at the time the credit was earned.

SECTION 4. Amends Section 901.312(a), Occupations Code, as follows:

(a) Authorizes TSBPA to accept the partial completion of the uniform CPA examination given by the licensing authority of another state if certain conditions are met, including if, at the time the credit was earned, the applicant met the requirements in effect in the other state and the other state's standards are equal to or higher than the standards prescribed by Chapter 901 (Accountants) or a rule adopted under this chapter.

SECTION 5. Requires TSBPA, as soon as practicable after the effective date of this Act, to adopt rules as necessary to implement the changes in law made by this Act to Chapter 901, Occupations Code.

SECTION 6. Effective date: September 1, 2025.

Senate Authors

Sen. Charles PerryRepublican · Primary Author

Coauthors (1)

Paul Bettencourt (R)

House Sponsors

Rep. Angie ButtonRepublican · Primary Sponsor

Joint Sponsors

Cosponsors (1)

Angelia Orr (R)

Bill Text(with markup)

S.B. No. 262

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

	AN ACT
	relating to eligibility requirements to practice public
	accountancy.
	BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS:
	SECTION 1. Section 901.252, Occupations Code, is amended to
	read as follows:
	Sec. 901.252. ELIGIBILITY REQUIREMENTS. To be eligible to
	receive a certificate, a person must:
	(1) satisfy the requirements of Section 901.253;
	(2) complete:
	(A) at least 150 semester hours or quarter-hour
	equivalents in board-recognized courses, including an accounting
	concentration or equivalent courses that meet the education
	requirements established under Section 901.254, as determined by
	board rule; or
	(B) a baccalaureate degree with an accounting
	concentration or equivalent courses that meet the education
	requirements established under Section 901.254, as determined by
	board rule;
	(3) pass the uniform CPA examination;
	(4) meet the work experience requirements established
	under Section 901.256; and
	(5) pass an examination on the rules of professional
	conduct as determined by board rule.
	SECTION 2. Section 901.256, Occupations Code, is amended by
	adding Subsection (a-1) to read as follows:
	(a-1) To be eligible to receive a certificate with a
	baccalaureate degree under Section 901.252(2)(B), a person must
	complete two years of experience as determined by board rule.
	SECTION 3. Section 901.258(a), Occupations Code, is amended
	to read as follows:
	(a) The board may accept the completion of the uniform CPA
	examination given by the licensing authority of another state if:
	(1) the examination was prepared and graded by the
	American Institute of Certified Public Accountants or, if doing so
	would result in a greater degree of reciprocity with the
	examination results of other states, the National Association of
	State Boards of Accountancy; and
	(2) the applicant met the requirements in effect in
	this state, as determined by board rule, at the time the credit was
	earned.
	SECTION 4. Section 901.312(a), Occupations Code, is amended
	to read as follows:
	(a) The board may accept the partial completion of the
	uniform CPA examination given by the licensing authority of another
	state if:
	(1) the examination was prepared and graded by the
	American Institute of Certified Public Accountants or, if doing so
	would result in a greater degree of reciprocity with the
	examination results of other states, the National Association of
	State Boards of Accountancy;
	(2) the credit is active in the other state; and
	(3) at the time the credit was earned, the applicant
	met the requirements in effect in the other state and the other
	state's standards are equal to or higher than the standards
	prescribed by this chapter or a rule adopted under this chapter.
	SECTION 5. As soon as practicable after the effective date
	of this Act, the Texas State Board of Public Accountancy shall adopt
	rules as necessary to implement the changes in law made by this Act
	to Chapter 901, Occupations Code.
	SECTION 6. This Act takes effect August 1, 2026.

LEGISLATIVE BUDGET BOARD
Austin, Texas

FISCAL NOTE, 89TH LEGISLATIVE REGULAR SESSION


February 17, 2025

TO:	Honorable Charles Schwertner, Chair, Senate Committee on Business & Commerce

FROM:	Jerry McGinty, Director, Legislative Budget Board

IN RE:	SB262 by Perry (Relating to eligibility requirements to practice public accountancy.), As Introduced

No significant fiscal implication to the State is anticipated.

It is assumed that any costs associated with the bill could be absorbed using existing resources.

The Board of Public Accountancyis a self-directed, semi-independent agency that is responsible for its costs of operations, prohibited from causing the General Revenue Fund to incur any cost, and not subject to the legislative budgeting process.

Local Government Impact

No significant fiscal implication to units of local government is anticipated.

Source Agencies:

457 Board of Public Accountancy

LBB Staff:

JMc, CMA, GDZ, DPE

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Frequently Asked Questions

Common questions about SB262

What does Texas SB262 do?

SB 262 fundamentally restructures the CPA talent pipeline in Texas by ending the exclusive "150-hour rule" and establishing a new licensure pathway requiring only a baccalaureate degree plus two years of work experience. This legislation compels public accounting firms and corporate finance departments to bifurcate their hiring, supervision, and retention protocols to accommodate two distinct classes of CPA candidates starting in 2026. Implementation Timeline Effective Date: August 1, 2026 Compliance Deadline: August 1, 2026 (Firms must be ready to process Track 2 candidates and apply new reciprocity standards immediately).

Who authored SB262?

SB262 was authored by Texas Senator Charles Perry during the Regular Session.

When was SB262 signed into law?

SB262 was signed into law by Governor Greg Abbott on May 8, 2025.

Which agencies enforce SB262?

SB262 is enforced by Texas State Board of Public Accountancy.

How urgent is compliance with SB262?

The compliance urgency for SB262 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.

What is the cost impact of SB262?

The cost impact of SB262 is estimated as "low". This may vary based on industry and implementation requirements.

What topics does SB262 address?

SB262 addresses topics including occupational regulation, occupational regulation--other trades & professions, public accountancy, texas state board of and accounting & accountants.

Legislative data provided by LegiScanLast updated: November 25, 2025

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