A state that has enacted the Counseling Compact is a member but cannot issue or accept privileges until it adopts rules, sets fees, gains FBI fingerprint authority, connects its licensee data to CompactConnect and passes testing. In October 2026, 29 states and DC were in that position; ten states were issuing.
A Florida LMHC wrote to us in the summer: "Florida passed the compact years ago. Why can't I apply?" The short answer is that a state joining the compact and a state issuing privileges are separate events, often years apart.
What does "enacted" actually mean?
A state is a member once its legislature passes the compact and the governor signs it. That makes the state a party to the agreement, gives it a seat on the Commission, and commits it to the compact's terms. It does not mean anyone in that state can apply for a privilege, or that anyone from elsewhere can get a privilege to practice there.
The Commission's answer to "why aren't all the jurisdictions going live at the same time?" lists what each state still has to do: adopt rules, establish fees, implement FBI background checks, prepare its IT systems, train staff, test data validation and build its application processes. Each of those runs on the state's own schedule, and some need further legislative or regulatory action.
Which states are in this position?
As of October 2026, these member jurisdictions had enacted the compact but were not issuing privileges:
Alabama, Colorado, Connecticut, Delaware, District of Columbia, Florida, Iowa, Kansas, Kentucky, Maine, Maryland, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, North Carolina, North Dakota, Pennsylvania, Rhode Island, South Carolina, South Dakota, Utah, Vermont, Virginia, Washington, West Virginia and Wisconsin.
That is 29 states and the District of Columbia. With the ten live states (Arizona, Arkansas, Georgia, Indiana, Louisiana, Minnesota, Ohio, Oklahoma, Tennessee and Wyoming) the membership is 40. Pennsylvania was the most recent to join: Governor Shapiro signed it on July 12, 2026.
What is the slowest step?
From the outside, the step that most often holds a state back is FBI fingerprint authority. Every member state must run criminal background checks on applicants for an initial privilege, and to search FBI records a state needs statutory authority that the FBI approves. Where a state's existing law does not cover the compact use, the legislature may have to amend it, and the FBI then reviews the language. Boards cannot shortcut that.
The rest is administrative but real. A board has to write and adopt rules through its normal rulemaking process, with notice and comment. It has to decide on a privilege fee. It has to send a clean, uniform data set on every licensee to the Commission's data system, and the Commission tests that data before switching a state on.
How fast has the gap closed?
The first two states, Arizona and Minnesota, opened on September 30, 2025. Ohio followed on January 5, 2026, then Louisiana (April 20), Georgia (June 2), Indiana (June 8), Arkansas (July 30), Wyoming (August 31), Tennessee (September 1) and Oklahoma (October 1). That is ten states in roughly a year, and the pace picked up in 2026. Still, at that rate, many of the remaining jurisdictions are unlikely to be issuing before 2027 or later, and no state has published a binding go-live date far in advance.
What should you do while you wait?
- If your home state is enacted but not live, the compact cannot help you yet. For any client you need to see in another state now, the route is a full license by endorsement or a full application. A license obtained now keeps working after the compact arrives.
- If the state you want to reach is not live, the same applies, even if your home state is. Privileges only run between two operating states.
- Get your home license compact-ready. Confirm it is at the independent clinical tier the compact requires, that there is nothing on it within the last two years, and that you have an FBI check on file if your board requires one for eligibility.
- Watch the board, not social media. Boards and the Commission announce go-live dates a few days to a few weeks ahead. Rumors on forums have been wrong more than once.
Does enacted status change anything at all for me?
A little. Some boards have already started compact rulemaking, and a board's rule drafts tell you what it will ask of privilege holders: a jurisprudence exam, a fee, any state-specific attestation. Kentucky's board, for one, has published a compact regulation. None of that lets you practice until the state is live and CompactConnect shows it as open.
Our Counseling Compact page keeps the live list current, and each state guide shows the compact status alongside the endorsement route. If you need to work in a state that is not live, we handle endorsement and full applications, and when the state switches on we can help you add a privilege instead of a second license next time.
Common questions
- My state passed the counseling compact. Why can't I apply yet?
- Enactment makes your state a member, but it still has to adopt rules, set a fee, secure FBI background-check authority and connect to CompactConnect. Until it goes live, licensees there cannot apply.
- Is Florida issuing counseling compact privileges?
- Not as of October 2026. Florida has enacted the compact but was not among the ten issuing states. Florida LMHCs who need another state now must apply for a license there.
- Can I get a privilege in a state that isn't live if my home state is live?
- No. A privilege only runs between two operating states. Your home state must be live, and so must the state where you want the privilege.
- When will Pennsylvania start issuing counseling compact privileges?
- No date had been announced as of October 2026. Pennsylvania joined on July 12, 2026, and still has to complete the same implementation steps every other state goes through.
Need Help with Your Application?
We handle the counselor licensing process end-to-end — eligibility screening, documents, board follow-ups, and tracking.