Behavior Analyst Licensure in Maryland: BCBA and State License Requirements

In the sections saved, Maryland creates a single credential: the licensed behavior analyst, defined as an individual licensed by the Board to practice behavior analysis.

Since January 1, 2015, an individual must hold that licence before practicing behavior analysis in the State.

The licence section's own exception is a student on an unpaid clinical educational experience, and § 17-6A-02 separately preserves the right of other Health Occupations Article licensees to practice their occupation within scope.

The licence authorizes its holder to practice while it is effective.

The sections read contain no associate, assistant or supervised tier, and no separate title-only provision — the operative restriction is on practice itself.

An applicant must be at least 18 years old and of good moral character, hold a current certification by the Behavior Analyst Certification Board or its successor, and have received a master's degree or higher from a behavior analysis educational program accredited by the BACB or its successor.

The Board may also require English competency and anything else it establishes by rule.

One waiver is written into the statute: an individual certified by the BACB on or before December 31, 2014, who is currently in good standing, does not have to meet the education requirement.

Beyond pointing to the BACB's accreditation, the sections read add no coursework or hour rule of Maryland's own.

The sections saved name no licensing examination of their own.

Section 17-6A-09(3) directs the Behavior Analyst Advisory Committee to develop, and recommend to the Board, criteria for a professional competency examination and testing of applicants for a license.

Whether the Board adopted an additional Maryland exam, or treats BACB certification alone as satisfying the exam side, would sit in the rules at COMAR 10.58.16, which the research did not read — it is not stated in the sources read.

Check the Board's application instructions before you file.

The sections saved have no assistant licence and no technician registration, so there is no supervised middle tier in them.

Practice outside the licence appears in two places in the sections saved.

Section 17-6A-02(b) does not limit an individual authorized to practice a health occupation under the Health Occupations Article who practices that occupation within scope, and § 17-6A-10(b) excepts a student enrolled in a program meeting § 17-6A-11(c)(2)'s education criteria while engaged in an unpaid clinical educational experience.

No exemption for technicians, paraprofessionals, school staff or family members appears in the sections saved, and no RBT provision.

A licensee can be disciplined for aiding or abetting an unauthorized person in practicing behavior analysis.

Whether COMAR 10.58.16 adds relevant provisions is not stated in the sources read.

The practice of behavior analysis means the design, implementation and evaluation of systematic instructional and environmental modifications to produce socially significant improvements in human behavior, including functional assessment and analysis and interventions grounded in scientific research and the direct observation and measurement of behavior and environment.

The definition expressly carves out psychological testing, diagnosis of disorders, psychotherapy, counseling and the other modalities listed below, so the licence is not a psychology or therapy licence.

Section 17-6A-02 also does not limit an individual authorized to practice a health occupation under the article who uses the terms behavior analysis or behavioral analysis within their own scope of practice.

The saved sections of Subtitle 6A contain no reciprocity or endorsement provision.

Every applicant, including a behavior analyst licensed in another state, qualifies through § 17-6A-11: current BACB certification and a master's or higher from a BACB-accredited program, unless the pre-2015 waiver applies.

That waiver is the closest thing to a moving provision in the sections read: it rewards tenure with the certifying body, not licensure elsewhere.

Whether the rules at COMAR 10.58.16 provide an endorsement path is not stated in the sources read.

Confirm the application requirements with the Board before assuming an out-of-state licence carries over.

A licence expires on a date set by the Board.

To renew, a licensee must otherwise be entitled to be licensed, pay the renewal fee set by the Board, file the renewal application, and submit satisfactory evidence of compliance with any continuing education requirements the Board establishes.

The statute authorizes CE but sets no total; the actual hour requirement is not stated in the sources read, because the Board's CE rules sit at COMAR 10.58.16, which was not read.

A licensee can move to inactive status and return by meeting then-current renewal and CE requirements.

A lapsed licence can be reinstated within 5 years after it expires; after that, the analyst must meet the current requirements for a new licence.

The substantive licence rules in the saved consolidation date to the subtitle's adoption, with the licence requirement in force since January 1, 2015.

What has moved recently is process.

The Board's behavior analyst page states that applicants must obtain a criminal history records check before submitting their application, and that beginning June 20, 2026 the Board transitions to an online-only application process, with the new portal launching July 1, 2026.

Neither change alters who qualifies; both change how you file.

Confirm the current filing steps on the Board's page before applying.

An application takes the Board's form, the application fee, and a criminal history records check under § 17-501.1 of the title.

The Board must issue a licence within 30 days of receiving a complete application that meets the requirements, or within 50 days after receiving additional information on one that was incomplete.

The Board's behavior analyst page tells applicants to obtain the criminal history records check before applying and to allow at least 30 to 45 business days for a completed initial application.

Behind the licence sits a five-member Behavior Analyst Advisory Committee — four BACB-certified analysts with at least 5 years of clinical experience and one consumer member — which recommends the regulations, ethics code, licence requirements and continuing education rules the Board adopts.