A certified public accountant sits close to client money, tax records, and financial statements that other people rely on. Because of that, a CPA candidate is usually screened twice: once by the state board of accountancy that issues and renews the license, and again by the firm that actually hires the person. These two reviews ask different questions, use different tools, and are governed by different rules. Understanding both helps firms build a hiring process that is thorough without overstepping the law.
Two separate screens, two separate purposes
The state board of accountancy decides whether a person may hold a CPA license at all. That review generally looks at education, examination results, experience hours, and a character or fitness component that can include a criminal history check. It applies to the individual, not to any one employer, and it follows that person across jobs.
The hiring firm runs its own background check as part of onboarding. This applies to CPAs and to non licensed accounting staff, bookkeepers, and support roles who never sit for the exam but still touch client funds or sensitive data. Firm level screening is a private employment decision governed by the Fair Credit Reporting Act (FCRA) and applicable state law, not by the licensing board.
State board licensing review: moral character and fingerprinting
Most state accountancy statutes ask an applicant to demonstrate good moral character, and many boards now pair that standard with a fingerprint based criminal history check rather than relying on self reporting alone. The specifics vary considerably by state, so a firm operating across state lines should expect different rules in each jurisdiction. Two state boards illustrate how differently the requirement can be built.
| State board | Who is fingerprinted | Databases checked | When it happens |
|---|---|---|---|
| Texas State Board of Public Accountancy | Active CPA licensees and non CPA firm owners, with limited exemptions for retired or disability status licensees | Texas Department of Public Safety and FBI records | Tied to the licensee’s birth month, ahead of the renewal deadline |
| California Board of Accountancy | Licensees who were not previously fingerprinted or who have no electronic fingerprint record on file with the Department of Justice | California Department of Justice state and federal criminal offender record information | Any time before license renewal, after a notice letter from the board |
Notice that neither board treats a criminal record as an automatic bar. Both are collecting information so the board can weigh it against the license, generally through the kind of individualized review described later in this article. A firm should never assume that a clean fingerprint result from the state board substitutes for its own hiring check, or the reverse. They answer different questions for different audiences.
What accounting firms screen beyond the license
Firm hiring checks typically cover several layers, and each one carries its own compliance obligation.
FCRA disclosure, authorization, and adverse action
When a firm uses a background screening company to pull a report on a candidate, the FCRA requires a clear, stand alone written disclosure that a report may be used in the employment decision, and the candidate’s written authorization before the report is requested. If the firm is considering rejecting the candidate because of what the report shows, it generally must send a pre adverse action notice that includes a copy of the report and the Summary of Rights, give the candidate a reasonable opportunity to respond, and then follow up with an adverse action notice if the decision stands. These duties apply to the hiring firm directly, not to whatever screening vendor it uses.
Credit checks
Because CPAs and accounting staff may have access to client bank accounts, payroll systems, or trust funds, many firms include a credit history review for roles with that level of financial responsibility. A credit check used for employment purposes is still a consumer report under the FCRA and requires the same disclosure and authorization steps described above. A number of states also restrict when an employer may use credit history in hiring at all, with exceptions that commonly cover financial services and fiduciary roles, so a firm should confirm its state’s rule before adding a credit pull to the process rather than assuming it is always permitted.
Criminal history
A criminal record search is standard for accounting hires, but a hit on the report should not automatically end a candidacy. Employers are generally expected to weigh the nature of the offense, how much time has passed, and how the record relates to the actual duties of the role before making a final decision, rather than applying a blanket exclusion. State law may add its own limits on how and when criminal history can be considered, so this is an area where firms often involve counsel rather than build a one size fits all rule.
Education and license verification
Firms should confirm the accounting degree, the credit hours claimed toward the state’s education requirement, and the CPA license status directly with the issuing board rather than taking a resume at face value. Most state boards publish a public license lookup tool for exactly this reason, and it is the fastest way to confirm a license is active, in good standing, and not carrying an open disciplinary action. Verifying a license and verifying a background check are related but separate tasks, and a firm’s process should include both.
Where PCAOB registration fits in
Firms that audit public companies register with the Public Company Accounting Oversight Board, a nonprofit created under the Sarbanes Oxley Act and overseen by the Securities and Exchange Commission. PCAOB registration and inspection focus on audit quality and firm level controls, not on running personal background checks on individual staff. A registered firm still has to build its own hiring screen the same way any other employer does. The PCAOB layer matters mainly because it raises the stakes on integrity and independence for staff working on public company audits, which is one more reason firms in that position tend to screen carefully rather than skip steps.
Building a process that holds up
A workable CPA hiring screen usually includes, in roughly this order: confirming license status through the state board’s public lookup, sending the FCRA disclosure and collecting written authorization, ordering the criminal history and, where relevant and permitted, the credit report, giving the candidate the pre adverse action notice and a chance to respond if a result raises a concern, and documenting the individualized review behind any final decision. Many firms route this through a consumer reporting agency, such as Reveal Background, so the disclosure, authorization, and adverse action steps happen in a consistent, documented order instead of being handled ad hoc by different managers.
Frequently asked questions
Do all state boards of accountancy require fingerprinting?
No. The requirement and its details vary by state. Some boards, including Texas and California, run fingerprint based criminal history checks against state and federal databases, while other boards may rely more heavily on application disclosures. Firms and candidates should confirm the current rule with the specific state board involved.
Can an accounting firm run a credit check on a CPA candidate?
Generally yes, for roles that involve financial trust responsibilities, but a credit check for employment is a consumer report under the FCRA and requires disclosure and authorization, and some states limit when employers may use credit history in hiring decisions. Confirm the applicable state rule before adding a credit check to the process.
Does a criminal record automatically disqualify someone from becoming a CPA?
Not automatically. State boards typically weigh a criminal history against the license application as part of a broader character and fitness review rather than applying an automatic bar, though the outcome depends on the offense and the specific state’s rules.
What is the difference between the state board’s screening and the firm’s background check?
The state board’s review determines whether a person may hold the CPA license and follows the individual across employers. The firm’s background check is a separate, private hiring decision governed by the FCRA and state law, and it applies to licensed and unlicensed staff alike.
Does PCAOB registration require its own personal background check process?
No. PCAOB registration and inspection apply to the firm’s audit quality and controls. Individual hiring screening is still handled by the firm itself, the same way it would be at any employer.
What should a firm verify about a CPA license before hiring?
At minimum, confirm the license is active and in good standing and check for open disciplinary history, using the issuing state board’s public license lookup tool, in addition to running the firm’s own background check.
Related reading
- Professional License Verification Background Checks: What Employers Need to Know
- Credit Checks for Employment: State Laws, FCRA Rules, and When They Apply
Sources
- Texas State Board of Public Accountancy, fingerprint requirement FAQ
- California Board of Accountancy, fingerprinting FAQs
- Federal Trade Commission, background checks: what employers need to know
- U.S. Equal Employment Opportunity Commission, enforcement guidance on arrest and conviction records
- Electronic Code of Federal Regulations, 12 CFR Part 1022, Regulation V (Fair Credit Reporting)
- Investor.gov, Public Company Accounting Oversight Board glossary entry
This article is general information, not legal advice. Background check and licensing rules vary by state and change over time, so confirm current requirements with the relevant state board of accountancy and, where needed, with legal counsel.
