Letter to VBOA on Inactive and Emeritus License Statuses
June 05, 2026
June 5, 2026
Nadia Rogers, CPA
Chair, Virginia Board of Accountanc
9960 Mayland Drive, Suite 402
Richmond, VA 23233
RE: VBOA Policy — Inactive and Emeritus License Status (Effective July 1, 2026)
Dear Chair Rogers:
On behalf of the nearly 11,000 members of the Virginia Society of CPAs (VSCPA), the VSCPA Executive Committee writes to follow up on our Dec. 3, 2025, letter regarding the draft VBOA policy on Inactive, Emeritus, and Expired/Suspended/Revoked License Status, and the Board's subsequent action at its Dec. 4, 2025, meeting.
We are grateful for the Board's responsiveness to the concerns raised in our letter, and we understood from the discussion at the Dec. 4 meeting that the policy would be revised to remove volunteerism restrictions for both CPA (Inactive) and CPA (Emeritus) licensees. The published policy reflects that revision with respect to the Emeritus status, and we appreciate that change. However, the volunteerism restriction for CPA (Inactive) licensees remains in the published policy.
As we noted in our Dec. 3 letter, we do not believe restrictions on volunteer activities beyond the prohibition on attest, compilation, financial statement preparation and compensated professional services are warranted for Inactive status licensees. For example, the position of volunteer treasurer on a Board of Directors is not typically a position requiring licensure as a CPA and may be filled freely by any person regardless of credentials. It is the type of role most commonly implicated by this restriction.
The practical consequences of the current policy language are particularly troubling when read in conjunction with Virginia's statutory definition of "using the CPA title." Under that definition, a licensee is considered to be using the CPA title by virtue of holding a license, regardless of whether the title is displayed or invoked in any way. The result is that a CPA (Inactive) is prohibited from volunteering in any financial capacity. The only way for the individual to serve as such is to either return to Active status, which requires 120 hours of CPE within the three years prior to reinstatement, or voluntarily surrender their license entirely. A person with no CPA credentials faces either of those barriers. A regulatory structure that punishes licensure in this way fails to serve the public interest, and we do not believe that outcome reflects the Board's intent.
We remain committed to working collaboratively with the Board on this and all matters affecting the profession in Virginia. We respectfully ask that the Board correct the policy prior to its July 1, 2026, effective date. If instead the differing treatment between CPA (Inactive) and CPA (Emeritus) status was intentional, we respectfully request that the Board revisit that decision and reconsider whether it is an appropriate restriction when the statutory language governing “using the CPA title” is also taken into account.
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