Why Understanding NASAA IAR CE Rule Changes Matters in 2025

The shifting landscape of NASAA IAR CE rule changes requires IA reps and RIA compliance teams to know about the changes. Unlike many regulators, however, NASAA does not publish a year-by-year change log. Instead, IARs and firms must parse each edition of the handbook to detect any adjustments year to year. This article extracts operationally significant changes you must know now, contextualizing them in verifiable history.

The Original IAR CE Architecture Remains The Same

NASAA's initial 2021 IAR CE handbook defined a durable framework for the program: 12 credits a year, evenly divided between Products & Practices and Ethics & Professional Responsibility. No exemptions no carryover, no grandfathering of CE classes taken last year. 

These basic components  remained unchanged. What has changed is how courses must be delivered, documented, and approved. In this sense, the program’s backbone remains stable while the administrative details have been refined in each new edition of the handbook.

The Hidden Nature of NASAA’s Updates Is Ironic

NASAA annually updates its IAR CE handbook but does not publish a summary of the revisions. Providers must read the full document each year to identify subtle yet impactful changes. 

Coincidentally, 12 hours after I wrote that sentence, the National Association of State Boards of Accountancy (NASBA) and the American Institute of CPAs (AICPA) released for public comment an exposure draft of proposed changes to its Statement on Standards for Continuing Professional Education (CPE) Programs (Standards) on September 17, 2025. 

NASAA IAR CE should promulgate rule changes the same way. Even if NASAA is not seeking comment on changes, giving it better exposure would be a big improvement.     

Moreover, NASAA has never issued a press release or stated in its annual reports or policy statements about how its IAR CE regulatory bulwark improves consumer protection. It has never  even explained the objectives of its IAR CE program to consumers! The state regulators now run an IAR CE program designed to help protect financial consumers in nearly half the states, but it has never explained what it is doing! I've looked!  NASAA is flying under the radar. 

While it's not saying anything about it publicly, NASAA now has administrative capabilities to enforce IAR CE rules in-house, including its own database system for maintaining IAR CE records.  Efficiently, the system leverages existing FINRA and IARD technology and integrated with interfaces for all IARs, IAR CE providers, instructors, FINRA and the SEC. Transcripts of completed classes are accessible online to IARs, for instance. To be clear, this giant national mechanism capable of regulating CE rules imposed on the nation's state registered IARs adopting its model rule, was built on a shoestring budget.   

NASAA now provides a highly credible new level of financial consumer protection shielding nearly half the states in the nation from financial crooks and unserious IARs.  

So it is indeed ironic that NASAA, a champion of transparency, has been hiding its greatly expanded role in protecting financial consumers across nearly half the American population with its IAR CE initiative. 

The is American capitalism at its very best. Yet NASAA isn't saying anything much about it. It's almost as if it's hidden its growing power. An ironic twist. 

August 2023: Engagement Okay for Live IAR CE Credit

Looking back at NASAA IAR CE Rule changes since the model rule became effective in January 2022 in three states, the most consequential update in recent years occurred on August 1, 2023, when NASAA dropped its requirement for exams on live classes. The rule now requires an engagement activity instead of testing. This change reduced friction for instructors and aligned the policy with CFP, CIMA, CPA financial advisors and other professional continuing education frameworks. It also permanently altered how CE sponsors must design live content. Among all NASAA IAR CE rule changes, this remains the one with the biggest impact on IARs and RIAs. Every provider must integrate an engagement activity, such as a poll, Q&A session, or other opportunity for IAR interaction. That's much easier than having to pass a 10-question assessment. 

Why the Engagement Requirement Matters Now

Today, NASAA requires providers of live courses prove IAR engagement by mandating evidence of one activity per IAR CE credit/hour, such as a poll. The engagement unscored. It is literally  designed expressly to show you're with the program.   

The live-course engagement requirement is embedded in the 2024 and 2025 handbooks. Not just embedded, the change is better described as buried in handbook minutia. better disclosure and more transparency is needed here. 

Dropping its testing requirement on live classes made NASAA's rule more uniform with CE and CPE requirements imposed on CFP, CIMA, CPA financial advisors, and other financial credentialed professionals. 

NASAA promulgates uniform laws and regulations and dropping the test requirement on live sessions was a step toward uniformity in favor of gaining widespread adoption. 

The IAR CE model rule was developed by a NASAA committee and is centrist and consensus-building by design.         

Evolution of Assessment Standards for Self-Study Courses

Assessment rules have also shifted. NASAA's initial 2021 handbook required a 100% passing score with unlimited attempts. Modern versions—codified by 2024 and carried into 2025—require a minimum score of 70%, earned within three attempts. If an IAR fails the assessment three times, they must retake the course. This same requirement is still in effect today. 

Administrative Changes Affecting Providers and Instructors

NASAA's administrative timeline has also evolved (read: changed significantly). Course approval must be requested 30 days in advance. Course validity lasts five years, but renewal is required annually. Providers must pay $35 annually to renew a class, with a full $250 re-review required every five years. These standards have remained consistent since being fully articulated in the 2024 handbook. While administrative, these policies shape day-to-day course operations and are an essential part of understanding NASAA IAR CE rule changes.

2025 IAR CE Handbook Consolidates—Rather Than Changes—NASAA's Requirements

The 2025 handbook introduces no new substantive requirements. It consolidates existing rules and enhances clarity around registration timing, CE deficiencies, and multi-state coordination. The minimum 12-credit requirement remains unchanged, as do the Ethics sub-requirements and engagement rules. While the 2025 edition is the authoritative text, its content reflects an evolution rather than a redesign. For firms, this is a stable year—one that allows implementation rather than adjustment.

NASAA IAR CE Rule Changes Annually Since 2021 Summarized

Below is a concise summary of documented, verifiable changes in each public edition.

What Firms Must Do Now Under the Current Standard

Today’s compliance burden centers on implementation, not discovery. Firms must ensure all live courses meet engagement requirements, all self-study courses follow the 70%/three-attempt rule, and all course submissions follow NASAA’s administrative processes. The 2025 framework is stable, but still opaque if firms rely solely on NASAA’s handbook. This executive summary clarifies key NASAA IAR CE rule changes so firms can focus on delivering compliant continuing education rather than decoding regulatory documents.