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ABA licensure by state: what your state asks for beyond your BACB certification

This guide covers seven states so far — Florida, Georgia, Illinois, Michigan, New York, Pennsylvania and Texas. We add a state once we have checked it at the state agency’s own page. If your state is not here yet, that does not mean it has no requirements — it means we have not checked it, and you should ask your licensing board.

Your BCBA certification is national. Your license isn't. Most states that license behavior analysts accept BACB certification as the core of the requirement, and then add something of their own that the BACB never asked you for. This page tracks that second part, because it's the part people find out about late.

Every state below was checked at the state agency's own page on 3 September 2026. We quote the agency rather than paraphrase it, and we name the agency so you can check it yourself. Rules change without notice and none of this is legal advice — confirm with your board before you rely on it.

The short version

StateLicenses behavior analysts?RenewalState-mandated training on top of BACB
TexasYes — LBA and LaBA (TDLR)Every renewal cycleHuman trafficking prevention, HHSC-approved
IllinoisYes — LBA and assistant (IDFPR)31 October of odd yearsSexual harassment prevention, 1 hour, every cycle
New YorkYes — LBA and Certified BA Assistant (NYSED)TriennialChild abuse identification & reporting, NYSED-approved provider
PennsylvaniaYes — Behavior SpecialistBiennialChild abuse recognition (Act 31), 3 h initial / 2 h renewal
MichiganYes — via LARA, Public Health CodeEvery renewal cycleImplicit bias training, 1 h per year of your cycle
FloridaNo in-state licenseNone at state level

Texas

Licensed Behavior Analyst (LBA) and Licensed Assistant Behavior Analyst (LaBA), via the Texas Department of Licensing and Regulation. At renewal, TDLR verifies your current certification and accepts it as your continuing education — and then requires one thing the BACB doesn't.

"A human trafficking prevention training course, approved by the Health and Human Services Commission (HHSC), must be completed to renew your license."
— TDLR, behavior analyst renewal page

TDLR's own list of covered license types names "Behavior Analyst, Behavior Analyst Assistant" alongside audiologists, dietitians, midwives and speech-language pathologists. It isn't a one-time course: it comes back at every renewal, and the course has to be on the HHSC-approved list. A good human-trafficking course that isn't on that list won't count — the approval, not the topic, is what your renewal checks. HHSC publishes the list and includes at least one free option.

Authority: Tex. Occ. Code ch. 116; HB 2059 (86th Legislature, 2019); rules at 16 TAC ch. 121.

Illinois

Licensed Behavior Analyst and Licensed Assistant Behavior Analyst, via IDFPR, under the Behavior Analyst Licensing Act. Two things here surprise people.

First, the sexual harassment prevention hour — and it doesn't wait for your CE cycle to start:

"Each individual (non-business) license holder must complete a one-hour sexual harassment prevention course during each renewal cycle, beginning with the first renewal after obtaining their initial license." … "This continuing education requirement applies to any individual (non-business) license holder under any licensing Act administered by the Department, even if the profession does not otherwise require continuing education credits for renewal, reinstatement, or restoration."
— IDFPR, continuing education

That last clause is the one to read twice. Illinois behavior analysts don't owe general CE until the 2027 renewal — but the harassment hour is owed at the first renewal regardless. Accepted sources are your employer, the Illinois Department of Human Rights training, or a continuing education provider authorized under an Act the Department administers.

Second, Illinois cares how the course is delivered: online CE has to include an examination, which rules out watch-only video libraries. Licenses expire 31 October of odd years; the first period can be shorter than two years, and after that it's a two-year cycle. Behavior analysts are also mandated reporters under ANCRA, with training required every three years.

New York

Licensed Behavior Analyst and Certified Behavior Analyst Assistant, via the New York State Education Department, Office of the Professions. New York requires coursework in identifying and reporting child abuse and maltreatment, and it's specific about who may teach it: the training has to come from a provider approved for that purpose by NYSED. The curriculum itself is written by the NYS Office of Children and Family Services, and approved providers present it. OCFS is an approved provider and offers the training free.

Unlike Texas and Illinois, this is generally a one-time requirement at initial licensure rather than something that comes back each cycle. One thing to watch: Chapter 25 of the Laws of 2024 amended the curriculum, so if you trained years ago, what you took may no longer match what's now taught.

Authority: Ch. 544 of the Laws of 1988, as amended; Soc. Serv. Law § 413 as amended by Ch. 56 of 2021 and Ch. 25 of 2024.

Pennsylvania

Pennsylvania reaches behavior analysts through its Behavior Specialist license, which sits with the health-related boards. That brings Act 31 with it: child abuse recognition and reporting training from a provider approved by the Department of Human Services. Unlike New York's, Pennsylvania's version recurs — three hours before initial licensure and two hours at every biennial renewal.

Watch for this one: two different Pennsylvania approvals are both called "Act 31." DHS approves the training curriculum, while the Department of State's Bureau of Professional and Occupational Affairs handles continuing education credit for licensed professionals. A course can carry one and not the other.

Authority: Act 31 of 2014; 49 Pa. Code § 33.256 / § 5.97; Child Protective Services Law § 6311.

Michigan

Michigan licenses behavior analysts under the Public Health Code, through LARA's Bureau of Professional Licensing. On top of your BACB certification, Michigan wants implicit bias training — and it comes back every cycle. Mich. Admin. Code R. 338.7004 requires "a minimum of 2 hours of implicit bias training within the 5 years immediately preceding issuance of the license or registration" for initial licensure, and for renewal "a minimum of 1 hour of implicit bias training for each year of the applicant's license or registration cycle."

The rule also says that "a licensee or registrant shall not carry forward implicit bias training hours earned during 1 renewal cycle to the next renewal cycle" — so you can't bank it. It applies to licensure under Article 15 of the Public Health Code, which is how Michigan reaches behavior analysts.

Florida

Florida doesn't license behavior analysts for in-state practice. It ran its own certification program from 1993 and handed it to the BACB in 2003, and it hasn't replaced it. In practice your BACB certification is the credential, and Medicaid reimbursement rules do the work a license would do elsewhere.

One wrinkle that's easy to misread: search Florida's Department of Health licensee registry and you will find behavior analyst entries — but every one of them is an out-of-state telehealth registration. That's a separate track for practitioners outside Florida delivering telehealth into it, with its own renewal. It isn't an in-state license, and finding it in the registry doesn't mean Florida licenses resident behavior analysts.

What we haven't checked yet

Most states license behavior analysts in some form. The five above are the ones we've verified at the agency's own page. We'd rather show you five we've checked than fifty we haven't, so we're adding states as we source them. If yours is missing and you need it next, tell us and it moves up the list.

A gap here means "we looked and didn't find it," never "we didn't look." Where a state has a requirement we couldn't confirm at source, we leave it out rather than guess — so treat a missing state as unchecked, not as clear.

Compiled by Special Learning, 3 September 2026. General information, not legal advice — confirm current requirements with your licensing board before you rely on them.