CBA committee delegates president to send comment on AICPA/NASBA CE standards exposure draft; AI references discussed

The Committee on Professional Conduct of the California Board of Accountancy voted Nov. 20, 2025, to delegate authority to the board president to issue a comment letter responding to an AICPA/NASBA exposure draft that proposes revised standards for continuing professional education (CE).

Sarah Benedict, manager of the renewal and continuing competency unit, told the committee the exposure draft — released Sept. 17, 2025 — reorganizes CE standards around seven principles and consolidates multiple delivery modes into a framework intended to promote measurable learning objectives and quality assurance. Benedict said staff support consolidating delivery modes and aligning CBA policy with the draft where appropriate, and recommended the board authorize the president to file the comment letter in attachment 1, including any CBA edits.

The draft does not explicitly use the words "artificial intelligence," Benedict said, but it frequently uses the term "technology," which “can be interpreted as AI.” She pointed to a provision requiring subject-matter experts to review any courses developed by technology before those courses can be approved. Committee member Bruce Raffel asked whether the standards should more directly reference AI; Raffel said he was concerned AI could replace roles now performed by humans and would like future standards to be more specific about AI. Benedict reiterated that the exposure draft contains no direct AI references but that several amendments implicitly address technology and recommended CBA staff continue aligning regulations and policy.

Staff also noted that the exposure draft differs from the Uniform Accountancy Act model rules and that the draft is targeted to CE providers while the model rules are regulatory text boards may adopt. Benedict said attachment 4 in the meeting materials maps the exposure draft to current California rules and highlights areas where future rulemaking might follow.

After hearing no public comments, the committee moved and seconded the staff recommendation. Miss Reid recorded affirmative votes from committee members, and the motion passed. The committee directed staff to proceed with the president-issued comment letter; Benedict said staff anticipate bringing additional proposed policy changes at a future meeting to further align CBA regulations with the standards.

The committee then moved to the next agenda item and adjourned later in the meeting.