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What a NASBA or NYSED evaluation means when it says you are short of credits

By the team. Checked 15 Nov 2026.

The short answer

In New York the two reviews do different jobs. A NASBA NIES evaluation can let you sit for the CPA exam. NYSED's own review of your original transcripts decides licensure, and its shortfall is the one you must close. Read which content area is short, then ask NYSED in writing what will close it.

Two reviews, two purposes

NIES evaluates international coursework for CPA exam and licensure applicants in more than 50 jurisdictions. In New York, NYSED lets candidates use NIES only to sit for the exam. For the licence, NYSED reads your original transcripts or mark sheets itself under 8 NYCRR 70.2 and does not accept outside evaluations.

ReviewWho does itUsed in New York for
NIES evaluationNASBA International Evaluation ServicesExam eligibility only
Licensure reviewNYSED Office of the ProfessionsThe CPA licence

Reading a shortfall

A shortfall usually names a number of semester hours and a content area. Read it in three parts: total hours toward 150, professional accounting hours toward 33, and general business hours toward 36. A candidate can meet one and fall short in another, for example 150 total hours but only 27 in general business.

  • Total: how far from 150?
  • Professional accounting: which of the four topics is missing?
  • General business: how many hours short of 36?

Why NIES and NYSED can disagree

Each reviewer converts foreign study to US semester hours and sorts courses into content areas using its own methods. A course NIES treats as business may be treated as general education by NYSED, or the other way round. When the two differ, plan to NYSED's finding, because that is the one that decides your licence.

A practical rule: treat the NIES report as a guide to the exam and an early warning, and treat the NYSED finding as the plan. If the NIES report already shows a gap, it is likely NYSED will find one too, so you can start asking questions early, but do not enrol in courses until NYSED has told you what it found.

What to ask NYSED

Write to the CPA unit or the Comparative Education Unit with your shortfall letter. Ask which subjects would close each part of the gap, whether the college you have in mind is acceptable, and whether online courses posted by that college would count. Keep the reply with your application papers.

  • Which subjects close each gap?
  • Is this college acceptable?
  • Will online courses it posts count?

The 2027 content change

From 1 August 2027 the content areas in 52.13 change. General business must include information technology and systems, business law, business data analytics, economics and finance, and the accounting list adds ethics and data analytics. If your licence review will fall after that date, ask NYSED which list applies to you.

Common mistakes after a shortfall letter

The most common mistake is taking courses before asking NYSED what will close the gap, and then finding that a course counts only as an elective. The second is choosing a college that will not post the credits in the way NYSED needs. The third is planning to an NIES report instead of the NYSED finding. Each is avoided by one written question before you enrol.

What to ask in writing

Before you enrol

Ask NYSED in writing which courses and which college will close your shortfall, and ask the college in writing which courses it will post, before you enrol.

UPI Study is not a college and is not accredited. ACE and NCCRS review our courses and recommend credit; a college decides whether to give that credit and records it on its own transcript.

ACE and NCCRS have over 2,100 cooperating colleges that will consider accepting credits; the final decision is with the universities.

Questions people ask

Do I need an NIES evaluation at all for New York?

You may use one to show eligibility for the CPA exam. For the licence, NYSED reviews your original records itself. Ask NYSED which route fits your timing, because some candidates apply for the licence review early to learn the shortfall sooner.

Who do I contact at NYSED about foreign education?

NYSED lists a Comparative Education Unit for foreign education questions, alongside the CPA unit of the Office of the Professions. Write to them with your shortfall letter and keep every reply with your application papers.

Can a shortfall finding change later?

NYSED reviews what you send. If you add records it did not see, such as a missing year's mark sheet, the finding can change. Send everything with Form 2 the first time to avoid a second review.

Courses that fit

ACE-recommended or NCCRS-recommended courses, studied online at your own pace.

Microeconomics course
Economics 251 · 3 credits · ACE-recommended

Microeconomics

Self-paced online Microeconomics course (Economics 251). ACE and NCCRS recommend 3 semester credits; each college decides how it applies them.

See the course →
Business Law course
Business 250 · 3 credits · ACE-recommended

Business Law

Self-paced online Business Law course (Business 250). ACE and NCCRS recommend 3 semester credits; each college decides how it applies them.

See the course →
Principles of Finance course
Finance 201 · 3 credits · ACE-recommended

Principles of Finance

Self-paced online Principles of Finance course (Finance 201). ACE and NCCRS recommend 3 semester credits; each college decides how it applies them.

See the course →

Start when you have it in writing

Close a general business or total-hour gap with ACE- or NCCRS-recommended courses, moved via a college transcript. Outside the US, ask the team about per-course or bundle prices.

Sources

  1. NYSED Office of the Professions: Initial licence for certified public accountants (official)NIES may review foreign education only to sit for the exam; for licensure the Department reviews original transcripts or mark sheets itself and does not accept outside evaluations (read via NYSED search extract; the page refused the certificate check). Checked on 15 Nov 2026.
  2. NASBA: About NIES (official)NIES evaluates international coursework for CPA exam and licensure applicants for over 50 jurisdictions; it does not evaluate for college admission or employment. Checked on 15 Nov 2026.
  3. 8 NYCRR 70.2: Professional education requirements for CPA licensure (eff. 28 Sep 2022) (official)150 semester hours for applicants from 1 Aug 2009; a baccalaureate or higher programme in accountancy or its foreign equivalent deemed substantially equivalent, as determined by the department; 120-hour exception for some applicants licensed in another state before 1 Aug 2009 who apply before 1 Aug 2027. Checked on 15 Nov 2026.