Letter to VBOA on Inactive, Emeritus and Suspended License Statuses

Dec. 3, 2025 

Nadia Rogers, CPA 
Chair, Virginia Board of Accountancy  
9960 Mayland Drive, Suite 402  
Richmond, VA 23233 

RE: Draft VBOA Policy — Inactive, Emeritus, and Expired/Suspended/Revoked License Status 

On behalf of the nearly 12,000 members of the Virginia Society of CPAs (VSCPA), the VSCPA Executive Committee has reviewed the draft VBOA policy addressing Inactive, Emeritus, and Expired/Suspended/Revoked License Status. We appreciate the Board’s attention to this important matter. After careful review, the Committee recommends that the policy not be approved in its current form. 

We strongly support providing clear guidance on the “inactive” license status and establishing a new “emeritus” license status. These distinctions — combined with requirements that licensees use the appropriate qualifier — are essential for protecting the public and encouraging CPAs to maintain licensure throughout their careers. However, we believe the policy’s proposed restrictions on volunteer activities are unnecessarily broad. CPAs holding inactive or emeritus status should be prohibited from performing attest, compilation, or financial statement preparation services. Likewise, individuals providing any services within the statutory definition of professional services for compensation should not qualify for inactive or emeritus status. 

Beyond these prohibitions, we do not believe additional limitations on volunteerism are warranted. Statutes and regulations already clearly define the practice of public accounting and the provision of professional services. Requiring CPAs with inactive or emeritus status to use the appropriate qualifier provides sufficient protection to the public. Our review of other states with inactive or emeritus/retired statuses indicates that they generally do not impose volunteer restrictions similar to those proposed. We have also heard from retired CPAs who are considering relinquishing their licenses due to volunteerism limits in the current policy. It is not in the profession’s interest to create conditions that encourage CPAs to give up their licenses out of concern for unintentionally violating volunteerism rules. 

In addition, we considered the broader national landscape, including heightened anti-regulatory scrutiny and growing concerns among multi-state firms. Many firms are increasingly reluctant to allow their CPAs to publicly display the CPA title due to varying state interpretations of allowable use. The policy in its current draft could be perceived by legislators and others as overly restrictive and counter to national trends. 

We appreciate the opportunity to comment and remain committed to collaborating with the VBOA and other stakeholders to shape the future of CPA licensure. Please feel free to contact me or VSCPA Vice President, Advocacy & Pipeline Emily Walker, CAE, at (804) 612-9428 or ewalker@vscpa.com if we can be of further assistance. 

Sincerely, 

Stephanie R. Peters, CAE
President & CEO 
Virginia Society of CPAs