Behavior Analyst Licensure in Hawaii: BCBA and State License Requirements
Hawaii licenses behavior analysts at a single level, the licensed behavior analyst, under HRS chapter 465D (2015).
The saved sections write no state degree or coursework rule: an applicant must have passed the BCBA examination, hold active BACB status as a BCBA or BCBA-D, and pay the director's fees.
There is no assistant licence — BCaBAs practise under an exemption — and no state registration for technicians; the implementer exemption is conditioned on holding the BACB's RBT credential.
Endorsement is available to licence-holders from another state whose requirements the director deems equivalent or higher.
Verify before you rely on this
At a glance
One licence: the licensed behavior analyst (HRS ch. 465D, L 2015, c 199).
There is no state assistant licence and no state technician registration.
Hawaii Department of Commerce and Consumer Affairs (DCCA), Professional and Vocational Licensing Division, Behavior Analyst Program; the director of commerce and consumer affairs issues the licence (§ 465D-8).
Yes.
The applicant must have successfully passed the Board Certified Behavior Analyst examination and maintains active status with the Behavior Analyst Certification Board as a board certified behavior analyst or board certified behavior analyst-doctoral (§ 465D-8).
None.
BCaBAs are exempt under § 465D-7(a)(3) when they implement or design applied behavior analysis services under the direction of a licensed behavior analyst, following the BACB's most recent supervisory and ethical requirements.
No state registration.
The direct-implementer exemption applies to an individual credentialed as a registered behavior technician by the BACB, under the direction of a licensed behavior analyst or licensed psychologist (§ 465D-7(a)(4)); it is the BACB credential, not a state one.
Not stated in the sources read.
The saved sections (HRS §§ 465D-2, -7, -8, -9) carry the definitions, exemptions, application and endorsement rules, but not the chapter's practice-restriction or title-protection section.
HRS chapter 465D, Act 199 of 2015 (L 2015, c 199); § 465D-7, the exemptions, last amended by L 2023, c 167, § 2, and § 465D-2 by L 2018, c 205, § 4.
The Hawaii credential ladder
- Registered behavior technician (BACB credential)(RBT)Other
Not a state credential: the chapter exempts an individual who directly implements applied behavior analysis services while credentialed as a registered behavior technician by the Behavior Analyst Certification Board and working under the direction of a licensed behavior analyst or a licensed psychologist (HRS § 465D-7(a)(4)).
- Board Certified Assistant Behavior Analyst (BACB credential)(BCaBA)Other
Not a state credential: Hawaii issues no assistant licence, so the BCaBA's place is an exemption — implementing or designing applied behavior analysis services under the direction of a licensed behavior analyst, in accordance with the BACB's most recent supervisory and ethical requirements (HRS § 465D-7(a)(3)).
- Licensed behavior analystIndependent
The one licence the chapter creates, issued by the director of commerce and consumer affairs to an applicant who has successfully passed the BCBA examination, maintains active status with the BACB as a BCBA or BCBA-D, and pays the fees the director establishes (HRS § 465D-8).
One licence, defined by the title and the licence itself
Hawaii issues one credential: the licensed behavior analyst.
Section 465D-2 defines the title by the licence — a licensed behavior analyst engages in the practice of applied behavior analysis, uses the title, was issued a licence under the chapter, and holds one that is in effect and not revoked, suspended, or encumbered.
The chapter creates no assistant licence and no technician credential; the people who may work without the licence are handled through the exemption list in § 465D-7 instead.
For a BCaBA or an RBT, the Hawaii question is therefore which exemption covers them, not which tier to apply for.
For how BACB certification and a state licence fit together, see BACB certification vs. state behavior analyst licensure.
“"Licensed behavior analyst" means a person: (1) Who engages in the practice of applied behavior analysis and uses the title of licensed behavior analyst; (2) Who has been issued a license under this chapter; and (3) Whose license is in effect and not revoked, suspended, or encumbered.”
The route: pass the BCBA exam, stay active with the BACB, pay the fees
The saved sections of chapter 465D (definitions, exemptions, application, endorsement) contain no Hawaii-specific degree, coursework or supervised-experience rule.
What the application turns on is the BACB: satisfactory evidence that the applicant meets the chapter's requirements and the rules adopted by the director, plus the three statutory items — passing the BCBA examination, active status with the BACB as a board certified behavior analyst or board certified behavior analyst-doctoral, and payment of the fees the director establishes.
The BACB's own degree, coursework and fieldwork requirements are national and are covered in the how-to-become article.
Whether the director's administrative rules add anything on top is not stated in the sources read.
The BACB’s own degree, coursework, fieldwork and exam requirements are covered in how to become a BCBA.
“The department shall issue a license under this chapter to an applicant for behavior analyst if the applicant provides satisfactory evidence to the department that the applicant meets the requirements for licensure contained in this chapter and rules adopted by the director and if the applicant for behavior analyst: (1) Successfully passed the Board Certified Behavior Analyst examination; (2) Maintains active status with the Behavior Analyst Certification Board as a board certified behavior analyst or board certified behavior analyst-doctoral; and (3) Pays all fees for licensure established by the director.”
The BACB's BCBA examination is the licensing exam
Chapter 465D names exactly one examination: the applicant must have successfully passed the Board Certified Behavior Analyst examination.
Because the requirement is written as a completed fact — passed, alongside current active status with the BACB — the exam is taken through the BACB before the Hawaii application, not administered by the state.
No Hawaii jurisprudence or law exam appears in the sections read, and whether the director's rules add one is not stated in the sources read.
Check the DCCA Behavior Analyst Program's application instructions before you file.
Working without the licence: the nine exemptions
Section 465D-7(a) lists the people the chapter does not reach, and the details decide who can implement and under whose direction.
A BCaBA is exempt when implementing or designing services under the direction of a licensed behavior analyst and following the BACB's most recent supervisory and ethical requirements (paragraph (3)).
A direct implementer is exempt when credentialed as a registered behavior technician by the BACB and under the direction of a licensed behavior analyst or licensed psychologist (paragraph (4)) — the exemption is conditioned on the BACB credential itself, not a state registration.
Only paragraphs (3) and (4) turn on a BACB credential.
Without one, an implementer is exempt only when another paragraph names them: the psychologist's supervisee (1), the classroom teacher (2), a family member, legal guardian or caregiver (5), a Medicaid-waiver implementer (6), nonhuman or nonpatient practice (7), a matriculated graduate student or postdoctoral fellow (8), or a person pursuing BACB experience (9).
For someone counting fieldwork hours, paragraph (9) decides supervisor choice: it applies only when a licensed behavior analyst supervises that experience.
“An individual pursuing experience in applied behavior analysis consistent with the Behavior Analyst Certification Board's experience requirements; provided that the experience is supervised by a licensed behavior analyst.”
What the practice covers — and the psychologist's title line
The practice of applied behavior analysis is defined as the design, implementation and evaluation of instructional and environmental modifications to produce socially significant improvements in human behavior, including functional assessment and analysis; the definition expressly excludes psychological testing, diagnosis of a mental or physical disorder, neuropsychology, psychotherapy, cognitive therapy, sex therapy, psychoanalysis, hypnotherapy and long-term counseling as treatment modalities.
Section 465D-7(b) then draws a title line inside the psychologist exemption: a licensed psychologist may practise applied behavior analysis in Hawaii, but not while held out to the public as a behavior analyst.
None of the saved sections states a general practice or title restriction beyond that — the part of the chapter that would say so was not among the sources read.
“Nothing in this chapter shall be construed to prevent any licensed psychologist from engaging in the practice of applied behavior analysis in this State as long as the licensed psychologist is not in any manner held out to the public as a "licensed behavior analyst" or "behavior analyst" and the behavior analysis services provided by the licensed psychologist are within the licensed psychologist's recognized scope of practice.”
Moving to Hawaii: endorsement at the director's judgment
A behavior analyst licensed elsewhere can ask for a Hawaii licence by endorsement, but the grant is discretionary — the director may issue it — and it is conditioned on the director deeming that jurisdiction's requirements equivalent to or higher than Hawaii's current requirements.
The licence must be current and unencumbered.
A BCBA who holds no behavior analyst licence in their former state does not use this route at all: they apply under § 465D-8 like a first-time applicant, with the BCBA exam, active BACB status and fees.
The sources read name no reciprocity or compact route besides endorsement.
“The director may issue a license by endorsement to an applicant who holds a current and unencumbered license as a behavior analyst in another state; provided that the requirements for a license in that state are deemed by the director to be equivalent to or higher than the current requirements for licensure in this State.”
Renewal: odd-year December deadlines, and a conflicting triennial line
The program's renewal page says to renew by December 31 every odd-numbered year: for the licensing period running January 1, 2026 to December 31, 2027, renewals were accepted November 3 through December 31, 2025, at $220.00 for active status or $12.00 for inactive.
The same page also prints that all licenses, regardless of issuance date, are subject to renewal triennial by June 30 every three years (2025, 2028, 2031), which does not match the odd-year calendar above it — confirm your renewal date with the program before relying on either.
A licence not renewed by its expiration date leaves the holder unlicensed and unable to practise, and a forfeited licence can be restored within one year ($320.00 active, $112.00 inactive).
No continuing-education requirement appears in the sources read.
Amended four times since 2015; what changed is not in the sources read
The chapter dates to Act 199 of the 2015 session (L 2015, c 199).
The history notes on the saved text show § 465D-7, the exemptions, amended by Act 107 and Act 123 of 2016, then Act 205 of 2018 and Act 167 of 2023, and the § 465D-2 definitions amended by Act 205 of 2018.
What those amendments changed is not stated in the sources read, so this page describes the sections as the current text prints them.
If you are working from a pre-2023 summary of Hawaii's exemptions, re-check it against the current § 465D-7.
What This Page Does — and Doesn’t — Cover
This page summarizes the Hawaii statute, rules, board pages and other documents cited above, as read for this state-by-state behavior analyst licensure series, current as of September 2026.
It does not list application forms, fees beyond those cited above, or processing times, and it is not a substitute for the instructions the Hawaii Department of Commerce and Consumer Affairs (DCCA), Professional and Vocational Licensing Division — Behavior Analyst Program publishes.
Hour totals, exams and supervision rules change by statute and by board rule; for how BACB certification and a state licence fit together, see BACB certification vs. state behavior analyst licensure.
Confirm every requirement with the Hawaii Department of Commerce and Consumer Affairs (DCCA), Professional and Vocational Licensing Division — Behavior Analyst Program before you count hours, register for an exam or apply — and before you take one of the board certified behavior analyst jobs in Hawaii that asks for it.
Frequently Asked Questions
I am a BCBA moving to Hawaii. Do I need a state licence?
Hawaii issues one credential, the licensed behavior analyst, and you apply for it through DCCA's Behavior Analyst Program.
Section 465D-8 requires a passed BCBA examination, active BACB status as a BCBA or BCBA-D, and payment of the director's fees.
If you hold a behavior analyst licence in another state, the director may grant a licence by endorsement under § 465D-9 when that state's requirements are equivalent to or higher than Hawaii's.
The exemptions in § 465D-7 are the chapter's stated exceptions to the licence.
Do RBTs need a Hawaii licence or state registration?
No state registration exists.
Section 465D-7(a)(4) exempts an individual who directly implements applied behavior analysis services while credentialed as a registered behavior technician by the BACB and working under the direction of a licensed behavior analyst or a licensed psychologist.
The exemption is conditioned on holding the BACB credential itself.
Without one, a person is exempt only through another paragraph that names them — for example a psychologist's supervisee, a classroom teacher, a family member or legal guardian, or supervised experience toward BACB certification (paragraphs (1), (2), (5) and (9)).
Employers and payers may set additional requirements of their own; confirm yours with DCCA.
I am a BCaBA. Is there an assistant behavior analyst licence in Hawaii?
No. Hawaii creates no assistant licence; the BCaBA's place is an exemption.
Under § 465D-7(a)(3), an individual who implements or designs applied behavior analysis services and holds board certification as an assistant behavior analyst from the BACB is exempt when practising in accordance with the BACB's most recent supervisory and ethical requirements and under the direction of a licensed behavior analyst.
Without that direction, the exemption does not apply.
Confirm your setup with the DCCA Behavior Analyst Program before starting work.
How often does a Hawaii behavior analyst licence renew?
The DCCA program's renewal page says to renew by December 31 every odd-numbered year: for the period running January 1, 2026 to December 31, 2027, renewals were accepted November 3 through December 31, 2025, at $220.00 active or $12.00 inactive.
The same page also prints a triennial line — June 30 every three years (2025, 2028, 2031) — that conflicts with the odd-year calendar, so confirm your date with the program.
A licence not renewed by its expiration date leaves you unlicensed and unable to practise.
Can teachers or school staff provide ABA in Hawaii without the licence?
A narrow exemption covers them.
Section 465D-7(a)(2) exempts a licensed classroom teacher — or an individual working as a classroom teacher while enrolled in a teacher preparation program toward licensure — who implements, but does not design, applied behavior analysis services in a school setting, in direct collaboration with a licensed behavior analyst or a licensed psychologist.
Designing programs, or working without that collaboration, falls outside the exemption.
Graduate students and supervised experience-seekers have their own exemptions in paragraphs (8) and (9).
More Hawaii & Board Certified Behavior Analyst Resources
Sources
- Hawaii Revised Statutes, chapter 465D (§§ 465D-2, -7, -8, -9), Hawaii Legislature (retrieved 2026-09-24)
- Hawaii DCCA, Professional and Vocational Licensing Division — Behavior Analyst Program (retrieved 2026-09-24)
Sourced from the statute, rules, board pages and other documents cited above.
Verified September 2026.
This is career information, not legal or clinical advice — confirm current rules with the Hawaii Department of Commerce and Consumer Affairs (DCCA), Professional and Vocational Licensing Division — Behavior Analyst Program.