Yellow Book CPE Requirements: What Auditors Need to Know

Certified Public Accountants (CPAs) and audit professionals who perform governmental audits under Government Auditing Standards, commonly referred to as the Yellow Book, must complete continuing professional education (CPE) that meets the requirements established by the U.S. Government Accountability Office (GAO) and aligns with generally accepted government auditing standards (GAGAS). Government Auditing Standards require auditors performing work under GAGAS to maintain professional competence through continuing professional education.

Yellow Book CPE requirements apply to professionals who perform work subject to Government Auditing Standards, including audits conducted under the Single Audit Act and Uniform Guidance (2 CFR Part 200 Subpart F) for entities like local government agencies. GAGAS applies when required by law, regulation, contract, agreement, or policy, and covers audits of government entities, programs, activities, and functions, as well as government assistance administered by contractors, nonprofits, and other nongovernmental entities.

This page provides general educational information to help CPAs understand how Yellow Book CPE requirements apply, including reporting periods, subject-matter requirements, annual minimums, and how these requirements interact with state CPA CPE obligations.

Yellow Book CPE Requirements at a Glance

The GAO guidance states that auditors performing work under GAGAS should complete at least 80 hours every 2 years, at least 24 of those hours in government-related subjects, and at least 20 hours in any 1 year of the 2-year period. It also states that excess hours may not be carried over to the next period.

Applicability: Who Must Follow Yellow Book CPE Requirements

Yellow Book CPE requirements apply to external and internal auditors, both government auditors and nongovernment, who perform audits or attestation engagements conducted in accordance with GAGAS. The GAO guidance says the focus is on the nature of the work being performed, not the individual’s job title.

These requirements typically apply to professionals who:

• Plan GAGAS engagements
• Direct or supervise GAGAS work
• Perform field work under GAGAS
• Report on GAGAS audits or attestation engagements

The guidance defines planning, directing, performing field work, and reporting, and states that auditors assigned to those activities should meet both the 80-hour and 24-hour requirements.

Yellow Book Continuing Education Requirements

For auditors subject to Government Auditing Standards, the GAO requires:

• 80 total hours of CPE every 2 years
• At least 24 hours directly related to government auditing, the government environment, or the specific or unique environment in which the audited entity operates
• At least 20 hours in any 1 year of the 2-year period

The GAO states that these requirements are intended to directly enhance the auditors’ professional expertise and proficiency to perform audits or attestation engagements.

Total CPE Hours Required

Yellow Book requires 80 total CPE hours every 2 years for applicable auditors. These hours should directly enhance the auditor’s professional proficiency to perform financial audits or attestation engagements under GAGAS.

Government Auditing Subject-Matter Requirement

At least 24 of the 80 hours should be in subjects directly related to:

• Government auditing
• The government environment
• The specific or unique environment in which the audited entity operates

This requirement comes directly from the GAO guidance and is meant to ensure auditors maintain competence in the government-specific aspects of their work.

Examples may include:

• Government Auditing Standards
• Uniform Guidance
• Single Audit requirements
• Internal controls over federal programs
• Compliance auditing and reporting

Auditors should use professional judgment to determine whether a course fits within the 24-hour government-specific requirement. The GAO guidance states that complying with the CPE requirements and selecting suitable CPE require auditors to exercise professional judgment.

Annual Minimum Requirement

Yellow Book does impose an annual minimum requirement.

Auditors performing work under GAGAS should complete:

• At least 20 hours of CPE in any 1 year of the 2-year period

This means the 80-hour requirement cannot be satisfied by completing all hours in a single year.

Additional Professional Competence Hours

After satisfying the 24-hour government-specific requirement, the remaining 56 hours should continue to enhance the auditor’s professional proficiency to perform audits or attestation engagements. The GAO emphasizes that CPE is part of the lifelong learning necessary for auditors to maintain professional competence.

These hours may include topics such as: financial statements, accounting and auditing

• Accounting and auditing
• Financial reporting
• Risk management
• Data analytics
• Other relevant professional topics

Limited-Applicability Exception

The GAO guidance includes an important exception for certain auditors with limited GAGAS involvement. As amended, auditors who are only involved in performing field work, are not involved in planning, directing, or reporting, and who charge less than 20 percent annually of their time to GAGAS audits and attestation engagements are required to complete 24 hours of training in each 2-year period in government-related subjects, but do not have to comply with the remainder of the 80-hour requirement.

Because this exception is narrow and role-specific, auditors should evaluate their responsibilities carefully before relying on it.

Professional Competence Requirement

Government Auditing Standards tie CPE directly to professional competence. The GAO states that the staff assigned to perform the audit or attestation engagement should collectively possess adequate professional competence for the task required, and that the success of an audit organization depends on having a competent, well-trained staff.

CPE is one part of that broader professional competence framework, alongside other professional development like certifications. Auditors should ensure that their education aligns with the nature of the work they perform and supports their ability to meet Yellow Book standards.

Self-Study Considerations

Yellow Book guidance recognizes a broad range of qualifying programs and activities, provided they meet the underlying standard of directly enhancing professional proficiency. Auditors are responsible for determining whether self-study CPE supports that purpose and for maintaining proper documentation.

Auditors should also confirm that any self-study CPE they claim under Yellow Book aligns with applicable state board requirements if they hold a CPA license.

Carryforward

Carryforward is not allowed under the Yellow Book CPE framework. The GAO guidance states that auditors may not carry over CPE hours earned in excess of the 80-hour and 24-hour requirements from one period to the next.

Relationship to State CPA CPE Requirements

Yellow Book CPE requirements apply in addition to state board of accountancy requirements.

This means:

• CPAs must still meet their state-specific CPE requirements
• Yellow Book CPE may count toward state requirements if it meets state criteria
• Additional state requirements, such as ethics CPE, may still apply

The GAO guidance includes a section on the relationship between GAGAS and other CPE requirements, reinforcing that auditors may be subject to multiple frameworks at once.

Yellow Book and Single Audit Requirements

Many Yellow Book engagements arise in connection with Single Audits under Uniform Guidance.

Uniform Guidance states that a non-federal entity expending $1,000,000 or more in federal awards during its fiscal year must have a single or program-specific audit conducted for that year, and that a single audit must be conducted in accordance with § 200.514 unless a valid program-specific audit election applies. Entities expending less than $1,000,000 are exempt from the federal audit requirement for that year, though their records must still be available for review.

Auditors performing these engagements are typically subject to Yellow Book CPE requirements, including the 24-hour government auditing component.

Reporting & Documentation

The GAO guidance addresses administration of the CPE requirements, including maintaining documentation, retaining records, preparing CPE reporting, and monitoring compliance. Auditors should maintain documentation supporting completed CPE, including course records, subject-matter classification, and hours earned.

CPE compliance may be evaluated through:

• Peer review
• Internal quality control systems
• Regulatory inspections or oversight reviews

Maintaining accurate documentation is essential for demonstrating compliance with Government Auditing Standards.

First Reporting Period / Applicability Timing

Yellow Book CPE requirements apply when an auditor begins performing work under Government Auditing Standards. Professionals newly assigned to governmental audits should evaluate whether their role falls within planning, directing, performing field work, or reporting on GAGAS engagements, because those functions determine whether the full 80/24/20 framework applies.

Yellow Book CPE Courses: What to Know

Auditors are responsible for:

• Completing 80 total hours every 2 years, if fully subject to Yellow Book
• Ensuring at least 24 hours relate to government auditing or the government environment
• Completing at least 20 hours in any 1 year of the 2-year period
• Maintaining documentation
• Aligning Yellow Book CPE with state CPA requirements where applicable

Because applicability depends on services performed, auditors should evaluate whether their work triggers Yellow Book requirements and whether any limited exception applies.

Audio-Based Self-Study and LumiQ

LumiQ provides CPE credits in an audio-based QAS Self-Study format designed to support CPAs and audit professionals through accessible, on-demand learning, similar to the flexibility offered by webinars.

While often described as a “CPE podcast,” LumiQ episodes are structured educational programs intended to support professional competence across accounting, auditing, risk, and compliance topics.

Auditors remain responsible for:

• Meeting Yellow Book requirements
• Properly classifying CPE
• Maintaining documentation in case of audit or review

LumiQ does not determine a licensee’s individual CPE requirements and does not provide regulatory or compliance advice.

Government Accountability Office (GAO) and Yellow Book Compliance

The U.S. Government Accountability Office establishes Government Auditing Standards, including Yellow Book CPE requirements. The GAO guidance explains who is subject to the requirements, how compliance should be measured, what qualifies as acceptable CPE, and how documentation should be maintained.

Auditors performing governmental engagements should ensure they understand and comply with applicable Yellow Book requirements.

Want more information: https://www.gao.gov/assets/143993.pdf 

Reviewed by Danielle Marion, Regulatory Compliance Manager at LumiQ. Danielle has more than 20 years of experience in regulatory compliance and professional education governance, including leadership roles at Deloitte LLP.