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Public Accounting Firms (CPA) Guidance and Forms

A firm is required to register as a public accounting firm with the Department if it:

  • Provides any attest or compilation services to NYS clients; or
  • Uses the words "Certified Public Accountant" or the designation "CPA" or the words "Public Accountant" or the designation "PA" in the firm name.
  • Registers as a professional entity to offer public accountancy services, such as, a sole proprietor, a Professional Corporation (PC), a Professional Limited Liability Company (PLLC), Limited Liability Partnership (LLP).

Effective June 8, 2024, the Business Corporation Law, Limited Liability Company Law and the Partnership Law was amended to allow Non-Licensee owners to be minority owners of CPA firms provided that, as applicable and required by law: 

  • at least a simple majority of the ownership of the firm, in terms of financial interests and voting rights held by the firm's owners, belongs to individuals licensed to practice public accountancy in some state; 
  • that all shareholders, members or partners of an entity whose principal place of business is in this state, and who are engaged in the practice of public accountancy in this state, hold a valid license issued under Education Law Article 149, §7404  of the education law; 
  • at least a simple majority of the directors are and were certified public accountants;
  • at least a simple majority of the officers are and were certified public accountants; and 
  • the president, the chairperson of the board of directors and the chief executive officer or officers are and were certified public accountants.

Firms registered with the Education Department may include non-licensed owners; however, a registered firm may not have non-licensed owners if the firm's name includes the words "certified public accountant," or "certified public accountants," or the abbreviations "CPA" or "CPAs." As such, firms will need to amend the name of their firm to remove the name of the profession prior to adding non-licensed owners. 

Each non-licensed owner of such firm shall be a natural person who actively participates in the business of the firm or its affiliated entities. “Actively participate" means to provide services to clients or to otherwise individually take part in the day-to-day business or management of the firm or an affiliated entity. "Affiliated Entity" means any entity controlled by, controlling or under common control with the firm.

There is a $900 fee for each non-licensed owner whose principal place of business is in New York State.  Any fees associated with non-licensed owners with a principal place of business in NYS will ONLY be collected upon initial incorporation, amendments to existing firms to add non-licensed owners and at triennial registration.

In addition to incorporation documents and amendments thereto, CPA Form 6R - Application for Public Accounting Firm Registration or Amendment to add Non-Licensee Owners to Existing Firm should be utilized for Registering a Public Accounting Firm and when amending an existing Public Accounting Firm to add Non-Licensee Owners to an existing firm.

CPA Form 6T- CPA Firm Triennial Registration should be utilized for triennial registration of Public Accounting Forms. Note that the Department mails out triennial renewals and annual updates 60 days prior to firm's anniversary date.

CPA Form 6C - Certification of Ownership and Attest Competency should be utilized for updating Certification of Ownership and Attest Competency annually when ownership has changed, outside of the firm’s annual or triennial registration for Public Accounting Firms. Note that there are no fees associated with FORM 6C. 

CPA Form 6PR - Peer Review, Competency, and Annual Statements is required to provide an annual firm update relative to Peer Review, Competency and Annual Statements.

Once a firm has been granted consent by the Office of the Professions, you must submit the following to the Professional Corporation Unit:

  1. A certified copy of the professional entity that has been filed in the records of DOS.
  2. Form 6R - Application for Public Accounting Firm Registration or Amendment to add Non-Licensee Owners to Existing Firm
  3. The appropriate firm registration fee as appliable, pursuant to instruction on Form 6R.
  4. Any other documents required by the NYS Education Department

Once an Amendment to an existing firm has been granted consent by the Office of the Professions, you must submit the following to the Professional Corporation Unit:

  1. A certified copy of the amendment that has been filed in the records of DOS.
  2. Form 6R - Application for Public Accounting Firm Registration or Amendment to add Non-Licensee Owners to Existing Firm
  3. The appropriate firm registration fee as applicable, pursuant to instruction on the form 6R.
  4. Any other documents required by the NYS Education Department

For more information relative to registering Public Accounting firms, please visit our CPA firm registration website here. 

Note that the Education Department cannot issue advisory opinions, answer hypothetical questions or provide legal advice. For questions related to professional practice entities, including the incorporation of such entities, please seek the legal advice of experienced counsel.