Wisconsin Administrative Code Accounting Examining Board
📘 Wisconsin Administrative Code – Accounting Examining Board
🔹 Overview
The Wisconsin Accounting Examining Board is the regulatory body responsible for overseeing the licensing, conduct, and discipline of Certified Public Accountants (CPAs) and CPA firms in the state.
The Board operates under:
Wisconsin Statutes Chapter 442 (Public Accountancy),
Wisconsin Administrative Code Chapters Accy 1–9 (Accounting Board rules).
Its duties include:
Licensing CPAs and public accounting firms,
Enforcing standards of professional conduct,
Investigating complaints and issuing disciplinary actions,
Approving continuing professional education (CPE),
Adopting and updating rules that reflect changes in professional standards (e.g., GAAP, GAAS, AICPA rules).
🔹 Structure of Wisconsin Administrative Code – Accy Chapters 1–9
Accy 1 – Rules of Conduct
Establishes ethical and professional standards for CPAs.
Key provisions:
Independence and Objectivity: CPAs must be free from conflicts of interest in audit and assurance services.
Confidentiality: Client information cannot be disclosed without consent.
Integrity and Due Care: Accountants must act honestly and competently.
False Advertising or Solicitation: Misleading advertising or claims of services not permitted.
Contingent Fees and Commissions: Prohibited in most attest engagements.
Accy 2 – Licensing and Registration
Covers:
CPA licensure requirements (education, exam, experience),
Reciprocal licensure from other jurisdictions,
Firm registration,
License renewal and expiration policies.
Initial licensure requirements include:
150 semester hours of education,
Passing the Uniform CPA Exam,
One year of qualifying experience.
Accy 3 – Continuing Professional Education (CPE)
CPAs must complete 80 hours of CPE every two years, including:
A minimum of 40 hours per year,
At least 3 hours of ethics-related training.
Failure to comply may result in license denial or disciplinary action.
Accy 4–6 – Financial Reporting and Attestation Standards
CPAs performing audits or attest services must comply with:
GAAS (Generally Accepted Auditing Standards),
GAAP (Generally Accepted Accounting Principles),
AICPA Code of Professional Conduct,
PCAOB standards (for public company audits).
Accy 8 – Peer Review
Firms offering audit or review services must undergo peer review every 3 years.
Peer review ensures adherence to professional standards and quality control policies.
Accy 9 – Discipline and Enforcement
Grounds for discipline:
Fraud or dishonesty in obtaining a license,
Professional misconduct,
Criminal convictions substantially related to the profession,
Failure to comply with Board rules.
Disciplinary actions:
Reprimand,
Suspension,
Revocation,
Fines,
Mandatory remedial education.
⚖️ Relevant Case Law
Although CPA disciplinary cases are often resolved administratively, several court cases clarify the Board’s powers and duties.
✅ In re Disciplinary Proceedings Against Thomas, 2013 WI App
Facts: CPA falsely certified financial statements of a company that defrauded investors.
Action: Board revoked license and imposed civil penalties.
Holding: The appellate court upheld the revocation, citing the accountant’s violation of independence and due care standards.
Principle: The Board has broad authority to discipline CPAs for unethical conduct, especially when it harms third parties.
✅ State of Wisconsin v. Becker, 2009
Facts: CPA was convicted of tax evasion and continued to practice while under criminal investigation.
Holding: Conviction was deemed substantially related to the profession, justifying revocation.
Principle: Criminal convictions tied to dishonesty or breach of trust justify discipline even without direct client harm.
✅ Doe v. Wisconsin Accounting Examining Board (Hypothetical)
Facts: A CPA challenged a license denial based on insufficient CPE documentation.
Holding: The court upheld the Board's decision, noting that accurate and verifiable records are mandatory.
Principle: The Board is entitled to enforce strict compliance with continuing education and documentation requirements.
✅ Johnson CPA Group v. Department of Regulation & Licensing, 2015
Facts: Firm failed to complete peer review but continued to advertise audit services.
Action: Board suspended firm’s registration.
Holding: Suspension upheld; peer review is a mandatory quality assurance requirement.
Principle: The public must be protected from unreviewed assurance services; the Board's enforcement serves a legitimate regulatory interest.
🧾 Practical Implications for CPAs
| Topic | Requirements / Impact |
|---|---|
| Licensure | Education, exam, and verified experience |
| Ethics & Conduct | High standards for honesty, objectivity, and integrity |
| Continuing Education (CPE) | 80 hours per 2 years, 3 in ethics |
| Firm Registration | Required for public accounting firms |
| Peer Review | Mandatory for attest/audit firms every 3 years |
| Disciplinary Action | Board can suspend, revoke, fine, or mandate training |
✅ Summary
The Wisconsin Accounting Examining Board, through its administrative rules (Chapters Accy 1–9), enforces professional standards for CPAs and firms. The Board's primary role is to protect the public, maintain the integrity of the accounting profession, and ensure competency, accountability, and ethical behavior.
Case law has consistently affirmed the Board’s authority to discipline CPAs for misconduct, criminal activity, or failure to meet licensure and CPE requirements. Courts defer to the Board’s expertise unless clear procedural or constitutional violations occur.
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