10. 29. 2026

One Market, Two Rulebooks

Every client I talk to hires as if "the US market" is one set of rules. It isn't. In my last piece, I wrote about why searches stall even when candidates exist: timing and the brief, not supply.

There's a second reason, and it has nothing to do with either. Take New York and Texas, two of the biggest markets Cobalt places finance and accounting talent into. They run on different rules for what you can ask a candidate, and for how that candidate became a CPA in the first place. If your firm hires across both, or anywhere in between, you're already working under more rulebooks than your hiring process assumes, and most hiring managers don't know which ones apply to them.

The Comp Conversation

New York has banned employers from asking a candidate's current salary since 2020, on top of a New York City ban in place since 2017. Since September 2023, most New York employers have also had to put a pay range on every job ad. Texas has neither law, at state or city level. Nationally, twenty-two states and twenty-four more cities and counties now have some form of salary history ban, each with its own effective date. In New York, the range leads the conversation. In Dallas, a client can simply ask.

Michigan and Wisconsin go the other way. Both states have barred their own cities from passing salary history bans at all. Comp law in the US isn't moving toward one national standard. It's moving in both directions at once, and a hiring process built for one market rarely transfers to the other intact.

CPA Eligibility

The other rulebook covers who can become a CPA in the first place, and it's changing faster. For decades, the license meant a bachelor's degree plus a fifth year of study, the 150-hour rule, which is widely blamed for the profession's recruitment problem. As of mid-2026, more than forty states have added a second route alongside it: a bachelor's degree plus two years of experience.

Texas and New York both made the change, on different dates. Texas's new pathway took effect on August 1, 2026. New York's takes effect on November 21, 2026, about three and a half months later. The two routes ended up nearly identical: roughly 120 credit hours plus two years of experience.

A fair number of candidates are still job hunting on pathway assumptions that are already out of date. Checking the target state's current requirement, rather than assuming 150 hours still applies, can mean a candidate qualifies sooner than they think.

The Data Center Boom Wants Your Accountants

There's a third pull on the same pool of talent. More than 66 gigawatts of data center capacity is under construction across North America, according to JLL's midyear 2026 report. About three-quarters of that pipeline (77%) now sits in what JLL calls frontier markets: power-rich regions outside the established hubs. Texas is taking the largest share of that shift, and JLL projects it could overtake Virginia as the world's largest data center market by the end of the decade.

Every one of those projects needs project accountants and finance managers as well as superintendents, and they hire from the same pool as real estate firms. For a Texas client, that's a new competitor for finance talent, and it often arrives before the client's own HR team has noticed it.

Read Your States Before You Post the Role

None of this is a reason to slow a search down. It's a reason to stop assuming "the US market" means one set of rules. Timing and the brief are the parts of a stalled search most clients recognize once they see them. This is the regulatory part of the same problem, and unlike those, it isn't a matter of judgment. It can be checked.

If you're hiring in more than one state right now, ask your Cobalt consultant to read your states before your next search goes live, comp law and CPA pathway both, and we'll tell you what's actually different. It's free, and it takes a lot less time than finding out mid-search. Or send us your brief. If you're a finance professional weighing your next move, see our live finance and accounting roles.

Frequently Asked Questions

Can employers ask about salary history in New York?

No. New York State has banned salary history questions since 2020, and New York City since 2017. Since September 2023, most New York employers have also had to include a pay range in job ads.

Can employers ask about salary history in Texas?

Yes. Texas has no salary history ban at state or city level, and no pay transparency law. A Dallas or Houston employer can ask a candidate what they currently earn.

When does the new CPA pathway take effect in Texas and New York?

Texas's pathway took effect on August 1, 2026. New York's takes effect on November 21, 2026. Both add a route of roughly 120 credit hours plus two years of experience, alongside the traditional 150-hour route.

How is the data center boom affecting finance hiring?

More than 66 gigawatts of data center capacity is under construction across North America, and about 77% of it is in frontier markets, with Texas taking the largest share. Each project needs project accountants and finance managers, so real estate firms in those markets now compete with data center developers for the same finance talent.