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What happens next? Understanding Iowa’s rulemaking process for CPA licensure pathways

August 21, 2026

HF 778 became effective July 1, 2026, creating an important new alternative pathway to CPA licensure in Iowa. But passage of the law was not the final step. The Iowa Accountancy Examining Board (IAEB) must also adopt administrative rules that put the legislation into practice.

That process is now underway.

The public comment period on the proposed rules closed July 28. The IAEB will consider comments received, determine whether changes to the proposed rules are appropriate and move toward final adoption. Under Iowa’s rulemaking process, rules generally cannot be adopted until at least 35 days after the Notice of Intended Action is published, and the process can take longer depending on the comments received and whether additional revisions are necessary.

Once the rules are adopted in final form, they are filed again with the governor’s administrative rules coordinator, published in the Iowa Administrative Bulletin and ultimately incorporated into the Iowa Administrative Code. The rules are also reviewed by the legislature’s Administrative Rules Review Committee. The overall Iowa rulemaking process takes a minimum of 108 days and includes required notice and publication periods.

For ISCPA, this stage of the process matters just as much as passage of HF 778. We are continuing to collaborate with the IAEB to help ensure the final rules reflect both the letter and the spirit of the legislation. Our advocacy is centered on three important priorities:

  1. Implementing the new alternative pathway as lawmakers intended.
  2. Preserving Iowa CPAs’ ability to practice across state lines through mobility.
  3. Protecting the two existing pathways to CPA licensure while adding this new option.

These objectives are closely connected. Iowa needs a licensure framework that creates more flexibility for future CPAs without unintentionally making it more difficult for Iowa CPAs to serve clients or employers in other states. We also want candidates to continue to have meaningful choices in how they qualify for licensure.

Rulemaking is a less visible part of the legislative process, but the details matter. How a statute is translated into administrative rules can significantly affect how the law works in practice.

ISCPA will remain actively engaged throughout the process, advocating for rules that support Iowa’s current and future CPAs, maintain mobility and uphold the strength and credibility of the CPA credential.

We’ll continue to keep members informed as the rules move through final adoption, publication and implementation.