Most U.S. attorneys must earn annual Continuing Legal Education (CLE) credits to maintain their licenses to practice. However, the demands of legal practice often overshadow CLE, leaving many attorneys scrambling to meet compliance deadlines—or worse, missing them entirely.
Noncompliance with CLE requirements can result in serious consequences, including license suspension. This guide provides an overview of CLE noncompliance rules and repercussions by state, helping attorneys take timely action to avoid penalties.
Alabama CLE Noncompliance
The Alabama Rules of Disciplinary Procedure, specifically Rule 10, governs noncompliance with the Alabama State Bar mandatory continuing legal education (MCLE) rules. First, the state bar will serve a lawyer who is not in compliance with a notice. If the lawyer does not come into compliance within 60 days of the notice, the disciplinary board will issue an order suspending the lawyer’s license. The lawyer may file an affidavit indicating compliance within 90 days of the suspension order. If the disciplinary board is satisfied with the affidavit, the lawyer will be reinstated. If the lawyer has been suspended for more than 90 days, the lawyer will have to file both an affidavit and a petition for reinstatement.
Alaska CLE Noncompliance
Alaska Bar Rule 66 governs noncompliance with Alaska’s CLE standards. An attorney who has received a notice of noncompliance has 30 days to complete the necessary credits, demonstrate that the notice was incorrect, or submit an affidavit of compliance. If none of these requirements are met, the attorney will be suspended. To be reinstated, the attorney must:
- comply with the CLE and reporting requirements,
- pay a reinstatement fee,
- pay any dues that accrued during the suspension, and
- have the compliance certified to the Alaska Supreme Court.
Arizona CLE Noncompliance
The Arizona State Bar will give a noncompliant lawyer notice. That lawyer will then have 30 days to comply with MCLE before being suspended. A suspended lawyer may be reinstated when the lawyer has completed the required CLE, along with payment of a reinstatement fee and payment of all delinquency fees.
Arkansas CLE Noncompliance
Rule 6 of the Rules for Minimum Continuing Legal Education governs noncompliance. The state bar will serve a noncompliant lawyer with notice. The lawyer then has 30 days to provide written evidence that they either did comply with the CLE requirements or have corrected the deficiency. If the lawyer fails to provide the required evidence, the Arkansas Continuing Legal Education Board may suspend the attorney’s license. An attorney who has been suspended and wants to be reinstated must file a petition for reinstatement.
California CLE Noncompliance
The California Rules of Court govern minimum CLE. A California attorney who does not meet the state’s CLE requirements will be moved to inactive status. To be reinstated, an attorney must submit:
- a completed MCLE compliance card,
- a noncompliance fee,
- a noncompliance reinstatement fee, and
- documentation of compliance.
Colorado CLE Noncompliance
If a Colorado attorney fails to comply with Colorado’s CLE rules, the Colorado Supreme Court will issue a statement of noncompliance to the attorney. The attorney has 14 days to either correct the noncompliance or request a hearing. If the attorney is still found to be noncompliant, the Colorado Supreme Court may suspend the attorney. If an attorney is suspended on this basis, they may be reinstated after correcting the deficiency and providing proof. The attorney must petition the Colorado Supreme Court for reinstatement and pay a reinstatement filing fee.
Connecticut CLE Noncompliance
Section. 2-27A of the Connecticut Practice Book governs minimum CLE in Connecticut. The state bar must give noncompliant attorneys at least 60 days to comply with CLE requirements before determining the appropriate action.
Delaware CLE Noncompliance
The Delaware Rules for Continuing Legal Education govern CLE noncompliance in Delaware. On or about January 15th, the Commission on Continuing Legal Education shall send a Notice of Noncompliance to each Attorney who did not complete the required CLE credits by the end of the preceding Compliance Year. At that point, the attorney must submit evidence of compliance. If the attorney fails to submit the evidence, the Commission will notify the Disciplinary Counsel. The Disciplinary Counsel will then determine the appropriate action.
Florida CLE Noncompliance
An attorney who fails to meet the annual Florida CLE requirement will be considered delinquent and not permitted to practice law in the state, according to the Rules Regulating the Florida Bar. A delinquent attorney may appeal to the Board of Governors of the Florida Bar. Attorneys who have been delinquent for fewer than five years are eligible for reinstatement. A delinquent attorney seeking reinstatement must file a petition outlining the reason for the delinquency and demonstrate good cause as to why the petition should be granted. The filing must also include a $150 reinstatement fee.
Georgia CLE Noncompliance
If a Georgia attorney is noncompliant with the state’s CLE requirements, the Supreme Court of Georgia will enter an appropriate order, including suspending the attorney from the practice of law. To be reinstated, the attorney must correct the deficiency and pay penalty fees and a reinstatement fee.
Hawaii CLE Noncompliance
Rule 17 of the Rules of the Supreme Court of the State of Hawaii governs CLE in the state. An attorney who has not completed the required CLE credits in a given year will be given a notice with an opportunity to become compliant. If the attorney fails to satisfy the CLE requirement, the attorney faces administrative suspension. The attorney may be reinstated upon completion of the required CLE credits and payment of a reinstatement fee, along with any other fees.
Idaho CLE Noncompliance
Section IV of the Idaho Bar Commission Rules governs MCLE in Idaho. The state bar will send a notice to any attorney who fails to meet the state’s CLE requirements. If the attorney remains noncompliant, the Idaho Supreme Court will cancel the attorney’s license, and the attorney will no longer be permitted to practice law in the state.
Illinois CLE Noncompliance
Rule 796 of the Rules on Admission and Discipline of Attorneys governs the enforcement of Illinois’s MCLE requirements. The director of administration will send a notice of noncompliance to an attorney who fails to submit MCLE certification within 31 days after the end of their reporting period. If the attorney doesn't provide proof of completing the CLE requirements or get an exemption, the attorney will be reported to the Attorney Registration and Disciplinary Commission (ARDC). The ARDC will then send notice that the attorney will be suspended from the practice of law.
An attorney who has been suspended due to noncompliance may be reinstated by the ARDC by filing a certification showing full compliance with MCLE requirements. The attorney must also pay a reinstatement fee and all other applicable fees.
Indiana CLE Noncompliance
Noncompliant attorneys face a $150 late fee for not meeting CLE requirements set by Rule 29 of the Indiana Rules for Admission to the Bar and the Discipline of Attorneys. If an attorney fails to complete the required CLE, the Indiana Supreme Court will issue an order suspending that attorney. The attorney may petition for reinstatement by completing their CLE requirements and paying a $200 reinstatement fee, in addition to any applicable surcharge.
Iowa CLE Noncompliance
Chapter 41 of the Iowa Court Rules governs CLE in Iowa. An attorney who fails to fulfill their CLE requirement may be suspended. Prior to suspension, the court must serve the attorney with notice of delinquency. The attorney will have 15 days to file an affidavit demonstrating that the noncompliance was not willful. The court may grant a hearing. If the attorney does not complete their CLE and has not been excused from fulfilling the requirement, the attorney may be suspended.
Kansas CLE Noncompliance
If an attorney in the state of Kansas has not earned the minimum number of CLE credits, the Office of Judicial Administration must send the attorney notice of the noncompliance. To avoid suspension, the lawyer must, within 30 days of the mailing of the notice, complete their CLE requirements or seek an exemption.
Kentucky CLE Noncompliance
CLE noncompliance in Kentucky is governed by Continuing Legal Education Rules SCR 3.675. The Continuing Legal Education Commission must provide notice to any attorney not in compliance with CLE requirements. If an attorney does not complete their CLE or file for an extension, the attorney will receive another notice. This notice requires the attorney to explain, within 30 days from the date of the mailing, why the attorney's license should not be suspended. If the lawyer cannot show good cause for the deficiency, the lawyer will be suspended. The lawyer may appeal the suspension to the Supreme Court of Kentucky or apply for restoration.
Louisiana CLE Noncompliance
The Rules of the Supreme Court of Louisiana govern MCLE. The Mandatory Continuing Legal Education Committee must mail a notice of noncompliance to an attorney who has not completed the required MCLE for the reporting period. Within 60 days of the notice being mailed, the attorney must provide proof that they are in compliance or file an affidavit explaining that there was good cause for the noncompliance. If the attorney does not complete the CLE requirements or get an exemption, the state supreme court may deem the attorney ineligible to practice law. The attorney may apply for review of any adverse decision by the Supreme Court of Louisiana.
Maine CLE Noncompliance
Rule 5 of the Maine Bar Rules governs CLE in Maine. The CLE committee will assess a noncompliance fee to an attorney who does not have the required CLE credits on the last business day of February. An attorney who does not meet the MCLE requirements may have their right to practice law suspended, but they may seek reinstatement.
Maryland CLE Noncompliance
Maryland recommends but does not require CLE.
Massachusetts CLE Noncompliance
Massachusetts recommends but does not require CLE.
Michigan CLE Noncompliance
Michigan recommends but does not require CLE.
Minnesota CLE Noncompliance
Rule 11 of the Rules of the Board of Continuing Legal Education governs noncompliance with Minnesota’s CLE requirements. The director of the Minnesota State Board of Continuing Legal Education will send a notice to a noncompliant attorney who fails to complete the required CLE credits or receive an exemption. An attorney who receives a notice has 30 days to request a hearing. If the attorney does not request a hearing, the director will report the attorney’s noncompliance to the state supreme court, recommending that the court place the attorney on involuntary restricted status.
Mississippi CLE Noncompliance
The Commission on Continuing Legal Education will notify each attorney who is not compliant with the state’s CLE requirements, according to the State of Mississippi Rules and Regulations for Mandatory Continuing Legal Education. A noncompliant attorney has 60 days to show cause as to why they should not be suspended. The commission will send the name of any attorney who does not show adequate cause to the state's supreme court, which will mete out sanctions. Note that an attorney can file an affidavit that they have met the CLE requirements any time after notification of noncompliance.
Missouri CLE Noncompliance
Any attorney who fails to meet the CLE requirements will be notified by mail in accordance with the Rules Governing the Missouri Bar and the Judiciary. Within 30 days of the notice, the attorney must send evidence demonstrating compliance. The attorney may request a hearing in front of representatives of the Missouri Bar. If the attorney fails to meet the CLE requirements, the Missouri Bar will report that attorney to the state's supreme court. The attorney reported to the court will be automatically suspended from practicing law. Once the attorney has met the CLE requirements, they will be reinstated.
Montana CLE Noncompliance
The Rules For Continuing Legal Education govern CLE in Montana. Any attorney who has not fulfilled the state's CLE requirements is transferred to inactive status and is reported to the Montana Supreme Court. The attorney must complete their CLE requirements and pay all fees before they can commission the Court for transfer back to active status.
Nebraska CLE Noncompliance
Per the Nebraska Supreme Court Rules, the state bar will notify an attorney of any noncompliance at least 45 days prior to the attorney’s suspension. The attorney will then have 45 days to come into compliance with the state’s CLE requirement. If the attorney does not come into compliance, the attorney will have to demonstrate why they should not be suspended. If the attorney does not offer a sufficient reason, the attorney’s name will be submitted to the Nebraska Supreme Court. The Nebraska Supreme Court will then order the attorney to provide evidence as to why they should not be suspended. If the attorney does not offer sufficient evidence, the Nebraska Supreme Court will then take action that it deems appropriate.
Nevada CLE Noncompliance
The Nevada Supreme Court Rules lay out the penalties for noncompliance with MCLE requirements in the state. An attorney who does not completely cure any deficiency 70 days after the last date of a written notice of noncompliance will be administratively CLE suspended. A suspended attorney may be reinstated by becoming compliant and paying the required fees.
New Hampshire CLE Noncompliance
New Hampshire recommends but does not require CLE.
New Jersey CLE Noncompliance
The Board on Continuing Legal Education will charge an attorney who has not completed the CLE requirement a noncompliance fee. The board will also give the attorney a grace period to complete their requirement. An attorney who remains noncompliant past the grace period will be charged an additional fee, be required to submit a reporting form, and must provide documentation proving compliance. Additionally, a noncompliant attorney may be declared administratively ineligible to practice law. To regain eligibility, the attorney must fulfill all required credits and pay the requisite fees.
New Mexico CLE Noncompliance
The Rules for Minimum Continuing Legal Education govern MCLE in New Mexico. The Judicial Continuing Education Committee will submit to the Supreme Court of New Mexico a list of attorneys who are not compliant with and not exempt from the state’s MCLE requirements. The court will then take action that it deems appropriate.
New York CLE Noncompliance
The New York State CLE Board’s CLE Rules govern continuing legal education in New York. The names of attorneys who are noncompliant with the state’s CLE requirements will be sent to the appellate division, which will determine the action to be taken.
North Carolina CLE Noncompliance
CLE requirements are 24 hours of approved CLE every two years. An attorney who does not satisfactorily complete the CLE requirements will receive a notice of noncompliance under the North Carolina Administrative Code.
North Dakota CLE Noncompliance
The State Bar of North Dakota regulates CLE in the state under the Continuing Legal Education Policies. Policy 5.9 governs noncompliance. The state will suspend any attorney who does not satisfy their CLE requirements.
Ohio CLE Noncompliance
The Supreme Court Rules for the Government of the Bar of Ohio govern CLE in Ohio. The Supreme Court Commission on Continuing Legal Education will notify an attorney who appears to be noncompliant. The attorney must provide evidence of compliance, or they may be sanctioned.
Oklahoma CLE Noncompliance
The Rules of the Supreme Court of the State of Oklahoma for Mandatory Continuing Legal Education govern MCLE in Oklahoma. Every year, the Commission on Mandatory Continuing Legal Education sends a list of all noncompliant attorneys to the executive director of the Oklahoma Bar Association. The executive director then serves each attorney with an order to show cause as to why the attorney's license should not be suspended after 60 days. If the attorney does not meet this requirement, the Board of Governors will recommend suspension to the Supreme Court. For a suspended attorney to be reinstated, the attorney must file an affidavit indicating compliance with the Rules for Mandatory Continuing Legal Education, as well as pay a $500 reinstatement fee.
Oregon CLE Noncompliance
The Rules of Licensure set by the Oregon Board of Governors of the Bar govern MCLE in the state. The Chief Executive Officer of the Board shall provide written notice to a licensee found in noncompliance. The notice shall set out a reasonable time to either request review of the noncompliance finding or to cure the noncompliance and shall state the amount of any late fee that must be paid by that time. The notice shall be sent to the licensee’s email address on file with the Bar or, for any licensee not required to have an email address on file with the Bar, to that licensee’s mailing address on file with the Bar. If the licensee fails to cure the noncompliance as required and pay the late fee within the time allowed, the licensee’s license is administratively suspended automatically.
Pennsylvania CLE Noncompliance
The Pennsylvania Continuing Legal Education Board will notify an attorney of their CLE deficiency. The board will then give the attorney 60 days to remedy the noncompliance. If the attorney remains noncompliant, the Board will report the noncompliance to the state's supreme court and recommend that the attorney be placed on administrative suspension.
Rhode Island CLE Noncompliance
Rule 3 in Article IV of the Rhode Island Supreme Court Rules governs MCLE. The MCLE commission will send a notification to any attorney who fails to fulfill MCLE requirements. The commission will then give the attorney 90 days to cure the noncompliance. If an attorney does not correct the noncompliance within 180 days of receiving notice, they will be removed from the Master Roll of Attorneys. The attorney may be reinstated within six months of being removed by completing the requisite courses, filing certification of proof with the MCLE Commission, and paying the necessary fees.
South Dakota CLE Noncompliance
South Dakota has no CLE requirement.
Tennessee CLE Noncompliance
Rule 21 of the Tennessee Supreme Court Rules governs CLE in the state. The Tennessee Commission on Continuing Legal Education will send any attorney who fails to meet their CLE obligation a notice requiring the attorney to cure the noncompliance. The commission will also charge a $100 fee. An attorney who fails to come into compliance by May 31 will have their name added to a suspension order. The suspension order will be sent to the state’s supreme court and the attorney. By Aug.10, the attorney is required to file an affidavit of compliance showing either compliance with MCLE requirements or a valid reason for exemption.
If the attorney does not satisfy their CLE obligation or obtain an exemption, the supreme court will suspend the attorney’s law license. An attorney may apply for reinstatement by demonstrating compliance with CLE requirements and paying the necessary fees.
Texas CLE Noncompliance
Rule 7 of the Texas MCLE Regulations governs CLE noncompliance. After the reporting deadline, the MCLE committee will give a noncompliant attorney a grace period to come into compliance with the MCLE requirements. An attorney who remains noncompliant will be given notice of noncompliance and required to pay a noncompliance fee. An attorney who is still noncompliant will be suspended from practicing law. An attorney who has been suspended may be reinstated by completing the necessary CLE credits and paying a reinstatement fee of $400.
Utah CLE Noncompliance
The MCLE Rules of the Utah Supreme Court Board of Continuing Legal Education cover noncompliance with MCLE requirements. The Utah State Board of Continuing Legal Education will submit a petition for the attorney's suspension to the state supreme court for any attorney who fails to complete their MCLE requirements. The attorney may request a hearing before the Utah State Board of Mandatory Continuing Legal Education. If the attorney is still found to be noncompliant, they will be suspended. A suspended attorney may be reinstated once they fulfill the MCLE requirements.
Vermont CLE Noncompliance
In Vermont, the Board of Continuing Legal Education will notify an attorney of noncompliance in accordance with the Rules for Mandatory Continuing Legal Education. An attorney may challenge the determination of noncompliance through a hearing in front of the board. If the attorney is still deemed noncompliant, the board will recommend suspension to the state's supreme court. A suspended attorney may be reinstated after they prove the CLE requirements are satisfied.
Virginia CLE Noncompliance
Regulation 109 of the Mandatory Continuing Legal Education Regulations governs MCLE noncompliance in Virginia. An attorney who is noncompliant with the state’s MCLE requirements may be subject to suspension. A delinquent attorney may regain good standing by demonstrating compliance or obtaining a waiver. The state supreme court may reinstate a suspended attorney once the attorney has paid the required fees and certified compliance with the MCLE rules.
Washington CLE Noncompliance
Washington’s supreme court may suspend a lawyer who does not timely certify MCLE compliance or receive an extension under Rule 11 of the Mandatory Continuing Legal Education Rules.
West Virginia CLE Noncompliance
An attorney who is not in compliance with MCLE requirements after July 1 will receive notice of their noncompliance under Rule 7.1 of the West Virginia MCLE Rules. The attorney will have until Oct. 1 to correct their noncompliance or demonstrate compliance. For any attorney who does not remedy the situation, the state supreme court may suspend that attorney’s license to practice law until the attorney complies with the MCLE requirements.
Wisconsin CLE Noncompliance
In Wisconsin, Supreme Court Rule 31 governs CLE. The Board of Bar Examiners is tasked with serving notice to any noncompliant attorney. The board will automatically suspend an attorney who has not complied within 60 days of being sent notice. A lawyer whose suspension for noncompliance under SCR 31.10(1) has been for a period of less than 3 consecutive years may file a petition with the 196 board for reinstatement to membership in the state bar.
Wyoming CLE Noncompliance
According to the Wyoming State Bar, an attorney who is not compliant with their CLE requirements by Jan. 15 will be considered delinquent and will face a $300 delinquency fee. A delinquent attorney has until March 1 to cure the delinquency and pay the fee. An attorney who does not cure the problem by March 1 will face suspension as well as an additional $300 noncompliance fee.
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