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

This page lists what the Montana 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.

Montana, field by field.

Board of accountancy

Montana Board of Public Accountants (Department of Labor & Industry, Business Standards Division)

CPE hours & reporting period

120 hours in each rolling three-year period ending December 31, with at least 60 hours (50 percent) in technical fields of study; no annual minimum stated; no routine reporting (random audit). ARM 24.201.2106(1): 'Active licensees are required to have 120 hours of continuing professional education (CPE) with a subset of two hours in ethics for the previous three-year period ending December 31 of each year, except as otherwise provided under ARM 24.201.2154.' ARM 24.201.2106(2): licensees 'affirm their understanding of the basic requirement upon annual renewal' for 'the three calendar years immediately preceding the renewal year.' ARM 24.201.2106(3): 'Beginning January 1, 2018, active licensees must complete a minimum of 50 percent (60 hours) of the total CPE hours required in technical fields of study as identified in ARM 24.201.2120.' ARM 24.201.2106(4): 'New licensees must meet the basic requirement of CPE by December 31 of the third year following the year of the initial issuance of the Montana license.' ARM 24.201.2106(6): 'A nonresident Montana licensee shall be determined to meet Montana CPE requirements by meeting the CPE requirements in the state where their principal place of business is located.' ARM 24.201.2145(1): 'Reporting of actual courses/credits is not required, unless the individual is selected for a random CPE audit as outlined in ARM 24.201.2148, or the individual must otherwise prove compliance for licensure purposes'. ARM 24.201.2124(3): 'Documentation must be retained for not less than five years.' Board page: 'All active permit holders are required to maintain 120 hours of CPE, including 50% technical subjects including two hours of ethics, to maintain an active license.'; Board CPE summary PDF (undated): 'You may earn up to 60 hours (50%) of the rolling three-year requirement as a lecturer, instructor, speaker, or technical reviewer. You may earn a maximum of 16 hours per year as a report reviewer. You may earn up to 30 hours (25%) for authoring published articles, books or other publications'.

Ethics CPE requirement

2 hours in each rolling three-year period, counted within the 60 technical hours; no Montana-specific course stated. ARM 24.201.2106(1): 120 hours 'with a subset of two hours in ethics for the previous three-year period ending December 31 of each year'. Board page: 'The mandatory 2 hours of ethics are included in the technical subjects.'; 'The two hours of ethics can be considered part of the 60 hours of technical subjects.' Board FAQ: 'The basic CPE requirement is 120 hours of acceptable CPE with a subset of 2 hours in ethics in any rolling three-year period.'

CPA firm permit / registration

Firm registration required for all firms with a Montana office; annual by December 31; firms without a Montana office are exempt under stated conditions (firm mobility). MCA 37-50-335(1): 'All firms that establish or maintain offices in this state for the practice of public accounting shall register annually with the department.'; 37-50-335(3): a firm with satellite offices in Montana 'shall provide a list of the location of each satellite office in this state at the time of annual registration.'; 37-50-335(4): a firm with no Montana office may use the 'CPA' or 'CPA firm' title and offer attest and compilation services in Montana without registering if it 'complies with the state's peer review and firm ownership qualifications;', 'performs the services through an individual with practice privileges under 37-50-325' and 'has practice privileges that include offering or rendering attest and compilation services' in the state of its principal place of business; (4)(b): other services through a person with practice privileges who has such privileges in the firm's home state. MCA 37-50-330(1)(b): 'a simple majority of ownership in the firm, in terms of equity and voting rights,' 'is held by accountants who are licensed in this state or in another substantially equivalent jurisdiction' or who meet 37-50-325; 37-50-330(4)(a): a firm no longer in compliance with the ownership requirements 'shall give notice to the board within 90 days of the noncompliance.' ARM 24.201.505(3): 'All firms must annually register with the board by December 31.'; ARM 24.201.505(1): 'New firms, firms that have a name change, or firms that are merged or otherwise combined or separated must immediately file a new firm registration application with the board.' Board page: 'All licensee's and firms under the Board, regardless of status, are required to renewal annually by December 31st.' Board mobility page: 'As of July 1, 2017, Montana is a firm mobility state.'

Peer review requirement

All registered firms performing audits, reviews, compilations, SSAE engagements or PCAOB-standard non-issuer engagements must enrol in a Board-approved peer review program; initial review due 18 months from enrolment; the cycle after the initial review is not stated in the rules read (ARM 24.201.1103, 1105, 1108). ARM 24.201.1103(1): 'All registered firms shall enroll in a board-approved peer review program and pay the required fees associated with the administration of the peer review, if they perform any of the following services:' '(a) an audit; (b) a review; (c) a compilation; (d) any examination, review, or agreed upon procedures engagements to be performed in accordance with the Statements on Standards for Attestation Engagements (SSAE); or (e) an engagement of a non-issuer performed in accordance with PCAOB standards and is not subject to PCAOB inspection.' ARM 24.201.1103(2): enrolled firms must authorize board access, via the sponsoring organization's secure web site, to the accepted peer review report, letter of response and acceptance letter within thirty days of acceptance. ARM 24.201.1103(3): the program must use 'AICPA Standards for Performing and Reporting on Peer Reviews or standards deemed equivalent by the board.' ARM 24.201.1103(4): 'A firm's due date for its initial peer review shall be 18 months from the date it enrolled or should have enrolled in a board-approved peer review program.' ARM 24.201.1108(1): exemption for 'out-of-state firms that do not have a physical location in this state, but perform attest or compilation services in this state, and have a peer review in the state in which they are located, and are otherwise qualified for practice privileges' and for 'firms that only prepare financial statements under SSARS and that perform no other attest or compilation services.' ARM 24.201.1105(1): a firm dropped from or terminated by a program 'shall have 21 days to provide written notice to the board'. Board page: 'The initial peer review is due 18 months from the date of enrollment, or the date the firm should have been enrolled (date began providing services).'; 'Currently the Nevada Society of CPAs administers the peer review program for Montana firms.'

Licence renewal cycle

Annual, by December 31. Board page: 'All licensee's and firms under the Board, regardless of status, are required to renewal annually by December 31st.'; 'Renewals not completed by December 31st are subject to late fees.' ARM 24.201.2106(2): CPE affirmation 'upon annual renewal'. ARM 24.201.410(1)(e): 'Renewal fee for licensee 125'; (1)(d): 'Renewal fee for certificate holder and inactive licensee 75'; (1)(f): 'Renewal fee for retired licensee 25'; (1)(h): 'License restored to active status 150'; (3): 'Application fees, renewal fees, and fees paid directly to a contractor are not refundable by the board.' Board FAQ: 'if you are licensed as a public accountant in Montana, you must hold a current active permit to practice in order to prepare tax returns' (citing 37-50-101(10), MCA).

Mobility / practice privilege

Practice privilege without a Montana licence; no notice, fee or other submission. MCA 37-50-325(1)(a): a person whose principal place of business is not in Montana and who holds a valid CPA licence from a state that NASBA's national qualification appraisal service has verified as substantially equivalent 'is presumed to have qualifications substantially equivalent to this state's requirements' and 'has all the privileges of persons holding a license of this state' 'without the need to obtain a license under 37-50-302'; 37-50-325(1)(b): the person 'is granted practice privileges in this state and no notice, fee, or other submission is required'; 37-50-325(2)(a): a licensee of a state not verified as substantially equivalent qualifies 'if the person obtains verification from the national association of state boards of accountancy's' 'national qualification appraisal service that the person's CPA qualifications are substantially equivalent'; 37-50-325(2)(c): the same no-notice, no-fee rule applies 'unless the person is required to register pursuant to 37-50-335'; 37-50-325(3)(a), (c), (d): the licensee and firm 'are subject to the personal and subject matter jurisdiction and disciplinary authority of the board;', 'shall cease offering or rendering professional services in this state individually or on behalf of a firm' if the home-state licence is no longer valid, and 'shall accept the appointment of the state board that issued the license as the agent upon whom process may be served'; 37-50-325(4): attest services or compilations for a client with its home office in Montana 'may do so only through a firm in compliance with 37-50-335.' ARM 24.201.531(2): 'The board has determined that all jurisdictions approved by NASBA are deemed to be "substantially equivalent."' ARM 24.201.527 (new rule effective March 7, 2026, MAR Notice No. 2025-350): 'The board adopts and incorporates by reference the 2025 substantial equivalency list for the Board of Public Accountants publication.'; 'The publication is available on the board's website.'; 'The board intends to review the publication annually.'; licence applications from individuals licensed in substantially equivalent states 'are routine applications as to the education, examination, and experience requirements for licensure.' (the 2025 list itself was not read in this pass). ARM 24.201.2106(5): a privilege holder 'must meet the CPE requirements applicable in the jurisdiction of his or her principal state.' Board mobility page: a CPA whose primary place of business is Montana is 'required to hold a Montana permit to practice.'; 'If Montana is not your primary place of business you do not need a Montana license' and such CPAs 'are not required to notify the Board office'.