Maryland: CPE, firm permit and peer review rules for CPAs.

This page lists what the Maryland board of accountancy publishes for a CPA and a CPA firm: CPE hours and the reporting period, the ethics requirement, whether a firm permit or registration is required, whether peer review is required, the licence renewal cycle, and whether an out-of-state CPA may practise under a practice privilege.

It is built for owners of small accounting and bookkeeping firms, especially those licensed in one state and serving clients in another. Every entry is a snapshot of what the cited source published on the verification date; it is a research starting point, not licensing advice.

Maryland, field by field.

Board of accountancy

Maryland State Board of Public Accountancy (Maryland Department of Labor)

CPE hours & reporting period

80 hours per two-year licence term, reported at renewal; no annual minimum is stated; no CPE is required for the first renewal. COMAR 09.24.02.03A: a renewal applicant must complete at least 80 credit hours of qualifying continuing education in each 2-year licence term before submitting the renewal application; 09.24.02.03B: the requirement does not apply to the first renewal. Bus. Occ. & Prof. §2-312: for each 2-year licence term after the first, a licensee must complete 'at least 80 hours in programs that the Board approves', continuing education does not apply to the first renewal, and hours beyond 80 in a term are credited to the following term. Board CE Basics page: an active CPA 'must earn a minimum of 80 qualifying hours of continuing education each license period' to renew; hours are reported at renewal and 'Licensees may only report credit hours earned up to the date the renewal application is filed.' Carry-forward: qualifying hours above 80 carry to the following two-year term only, up to a maximum of 80 (COMAR 09.24.02.03D–E), and up to 80 hours earned in the initial term carry forward if reported on the first renewal (09.24.02.03F). Documentation is retained for four years (Board CE Basics page). Exceptions for health, military service or other good cause (COMAR 09.24.02.06). Board FAQ: 'On the first renewal, you do not need to have taken any CE to renew.'

Ethics CPE requirement

4 hours per two-year licence term; no Maryland-specific course is stated. COMAR 09.24.02.03C: 'A minimum of 4 credit hours of the continuing education for each 2-year license term shall be in professional ethics.' Ethics hours above 4 count toward the 80-hour total but cannot be carried forward to meet the next term's ethics requirement (COMAR 09.24.02.03C). Board CE Basics page: four of the 80 hours must be in professional ethics in each two-year period, and ethics hours above four 'can be used as ordinary CE.'

CPA firm permit / registration

A firm permit is required for a firm with a Maryland office that performs attest services or uses the 'CPA' or 'CPA firm' title; sole practitioners are exempt; permits run two years from issuance. Bus. Occ. & Prof. §2-401(a): a firm must hold a permit if it has an office in the State that performs attest services as defined in §2-101(c) or an office in the State that uses the title 'CPA' or 'CPA firm'. §2-401(b): a firm with no Maryland office may perform attest services for a Maryland client without a permit if it meets the application and peer review requirements under §§2-402, 2-402.1, 2-403 and 2-4A-02 and performs the services through an individual with a practice privilege under §2-321. §2-401(d): a firm that does not meet the section's requirements may perform professional services other than attest services and use the 'CPA' or 'CPA firm' title in Maryland without a permit through an individual with a §2-321 practice privilege. Board firm-permit page: a sole practitioner, including one organized as a CPA firm, 'does not have to obtain a permit' (§2-602); a simple majority of the firm's owners by financial interest and voting rights must be actively licensed CPAs in any state and all non-CPA owners must be active participants in the firm; 'The permit period is two years from the date of issuance.'; the page cites §§2-401 through 2-404 and COMAR 09.24.04.01–.04. The same page states that 'CPA firms that provide certified public accountancy services to Maryland clients must obtain a permit from the Board.' and that the requirement also applies to out-of-state CPA firms, which is narrower than §2-401(b). Board firm-mobility notice: 'Effective October 1, 2019, as a result of House Bill 1081 and Senate Bill 513,' CPA firms licensed in another state without a Maryland office do not need a Maryland firm permit if they meet the application and peer review requirements and perform the services through an individual with practice privilege.

Peer review requirement

Licensees and permit holders performing the services listed in §2-4A-04 undergo peer review at least once every three years and affirm compliance at renewal. Bus. Occ. & Prof. §2-4A-02(a)(1): a licensee or permit holder who performs any of the services described in §2-4A-04 'shall be required to undergo, at least once every 3 years, a peer review'; (a)(2): the Board may modify the requirement for good cause; (b): standards 'no less stringent than' the AICPA's; (c): the Board must approve any peer review program other than the AICPA's before it is used; (d): at each renewal the licensee or permit holder affirms compliance 'under the penalties of perjury on a standard form provided by the Board'. §2-4A-04(a) (system review) covers audit engagements under the AICPA Statements on Auditing Standards, engagements under GAO government auditing standards, examinations of prospective financial information, and audits of issuers not registered with the SEC under PCAOB standards; §2-4A-04(b) (engagement review) covers reviews of historical financial statements under SSARS, compilations of historical financial statements with or without substantially all disclosures, and AICPA attestation engagements other than examinations of prospective financial statements. Board Peer Review page (reachable on 2026-10-14): 'Peer reviews are performed every three years.'; the period for which a review is valid is determined by comparing the date on the peer review acceptance letter with the licence or permit renewal dates; the Board has approved the 'Maryland Association of Certified Public Accountants (MACPA) Peer Review Program' and recognizes other states' AICPA-approved programs; 'Licensees and permit holders are required to certify every renewal time that they have undergone a peer review.'; CPAs and firms that only do tax preparation, accounting, consulting or bookkeeping 'do not have to undergo a peer review.' The Board page describes the covered work as audits or engagements under the attestation standards, while §2-4A-04(b) also lists SSARS reviews and compilations.

Licence renewal cycle

Two-year licence term. Bus. Occ. & Prof. §2-311(a)(2), as read on the legislature's site: unless renewed for a 2-year term, 'the license expires on the first December 31 that comes' after the effective date of the licence and in an even-numbered year; §2-311(e): the Secretary may determine that licences under the subtitle expire on a staggered basis. §2-311(b)(1): 'At least 1 month before a license expires, the Board shall mail or electronically transmit to the licensee' a renewal application and a notice of the expiration date and fee. §2-311(c): renewal for an additional 2-year term requires that the licensee otherwise is entitled to be licensed, pays the licence fee and submits 'satisfactory evidence of compliance with the continuing education requirements set under this subtitle'. §2-311(a) does not apply to a CPA on emeritus status under §2-313.1. Board FAQ: a licensee 'can renew their license up to 60 days prior to the expiration date to avoid paying the reinstatement fee'; reminders are sent at 60, 45, 30, 15 and 5 days before expiration; 'On the first renewal, you do not need to have taken any CE to renew.' Board renew/reinstate page: 'If your license is now expired, you will only be renewing your license for the remainder of the current license term.' and 'The continuing education (CE) hours you report now will expire on the date of the current license term.'

Mobility / practice privilege

Yes, without notice, fee or submission. Bus. Occ. & Prof. §2-321(b): a CPA 'whose principal place of business is outside the State' who holds a valid licence from another state and passed the Uniform CPA Examination is exempt from the §2-301 licensing requirement and has all the privileges of a Maryland licensee; §2-321(c)(2): the privilege applies 'without any notice, fee, or other submission to the Board'; §2-321(d): the individual and any employing firm consent to 'the personal and subject matter jurisdiction and disciplinary authority of the Board', to comply with Maryland public accountancy law and Board regulations, to appoint the home-state board as agent for service of process, and to stop providing services if the home licence is no longer valid; §2-321(f): a sole practitioner under the privilege may perform attest services only through a firm that holds a permit under §2-401. Board mobility page: mobility applies to CPAs who are 'actively licensed' and whose 'principal place of employment is in another state'; such CPAs must comply with the Maryland Public Accountancy Act and related regulations (§2-321); firm mobility applies 'As of October 1, 2019' to firms meeting §§2-402, 2-402.1, 2-403 and 2-4A-02 and practising through a §2-321 individual.