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Committee clarifies inactive-status rules, removes "one employer" restriction
Summary
Draft edits would allow inactive licensees who are W-2 employees to work for multiple employers (e.g., bookkeeping roles) while maintaining limits on public practice and ownership; committee debated wording and agreed to remove "lapsed" and "active" inconsistencies.
The committee reviewed proposed revisions to the inactive-license rules, focusing on language that previously limited inactive licensees who work in private industry or government to practicing public accountancy for only one employer.
Members said the board wanted to remove a strict "one employer" limit so that W-2 employees who perform bookkeeping or similar staff functions for multiple employers would not be unintentionally barred. Committee counsel explained the intent: an inactive licensee may perform work for an employer as staff (e.g., CFO or similar positions) but may not hold ownership or provide public-accounting services as a firm owner.
Committee members also identified drafting issues: several sections used the term "active" or included "lapsed" where it created unintended barriers (e.g., moving between lapsed and inactive status). The committee instructed staff to remove the word "active" in drafting and to take out "lapsed" where it conflicted with reinstatement practice. Staff will return with a harmonized set of edits clarifying application, renewal, reporting and reinstatement processes for inactive licensees.
