At its September 12, 2025 meeting, the Indiana Board of Accountancy officially approved a non-rule provision that provides much-needed clarity on how Indiana evaluates substantial equivalency. This move ensures CPAs can continue to move freely across state lines to serve clients and apply for reciprocal licensure—without unnecessary barriers or confusion.
The provision will be effective immediately once it is formally published in the Indiana Register on October 1, 2025.
Wait—What’s a Non-Rule Provision?
In Indiana, a non-rule provision (sometimes called a non-rule policy document or NPD) is an official statement issued by a state agency – in this case, the Indiana Board of Accountancy – to explain how it interprets and applies a law or administrative rule. Unlike formal rules, non-rule provisions are not legally binding, but they are still published publicly and treated as agency guidance.
Here’s a quick breakdown:
- Clarifies law: Offers insight into how an agency interprets existing law or rules.
- Not enforceable like a rule: It doesn’t carry the force of law but helps the public understand agency policy.
- Publicly posted: Must be published in the Indiana Register (and often on the agency’s website).
- Grounded in statute: Authorized under Indiana Code § 4-22-7-7(a)(5).
In this case, the Indiana Board of Accountancy is using a non-rule provision to confirm how it will apply Indiana’s “substantial equivalency” standard for mobility and reciprocity—without needing to wait for the full rulemaking process.
Why It Matters
Earlier this year, Indiana took a major step forward with the passage of HEA 1143, which added a third, modern pathway to CPA licensure. That change doesn’t go into effect until January 1, 2027, but other states, including some of our neighbors like Ohio, are rolling out new pathways quickly.
Without guidance from the Indiana Board of Accountancy, we risked creating uncertainty for out-of-state CPAs and the Indiana employers who rely on them. That’s why we submitted a request for this non-rule provision and the Board delivered.
What the Provision Says
The non-rule provision confirms that out-of-state CPAs will continue to meet Indiana’s standard for substantial equivalency, as long as they:
- Passed the Uniform CPA Examination, and
- Obtained their original license through one of the following education and experience combinations:
Pathway 1
A post-baccalaureate degree in accounting and at least one year of verified experience
Pathway 2
A 150-hour baccalaureate degree in accounting and at least one year of verified experience
Pathway 3
A baccalaureate degree in accounting with fewer than 150 hours and at least two years of verified experience
This clarification applies to both mobility (working in Indiana while licensed and living elsewhere) and reciprocity (getting licensed in Indiana but already hold an active out-of-state license). It ensures Indiana is aligned with other states, supports business continuity, and avoids potential disruptions for professionals and firms alike.
What It Means for You
Whether you’re:
- A firm leader hiring remote or out-of-state staff,
- A licensed CPA serving clients in Indiana, or
- A regulator or recruiter navigating cross-border practice.
This provision keeps Indiana in step with the national direction, especially as more states revise their licensure frameworks. It also sends a strong message: Indiana is open for talent, supportive of mobility, and committed to a future-ready CPA profession.
Questions or Need Support?
The Indiana CPA Society worked closely with our Government Relations Advisory Council, Board of Directors, and the Indiana Board of Accountancy to make this happen. We’re here if you have questions or want help understanding how this may affect your work.
Contact us anytime:
We’re proud to be at the forefront of licensure modernization, and we’ll continue working hard to support Indiana CPAs every step of the way.