Behavior Analyst Licensure in Washington, DC: BCBA and State License Requirements
Washington, DC added a behavior analyst licence in 2024.
D.C. Code §3-1207.71 directs the DC Board of Psychology to license as a behavior analyst anyone who completes a criminal background check, holds current BACB certification, and holds a master's degree or higher from a behavior-analysis program the statute describes as accredited by the BACB — waived for anyone certified on or before July 19, 2024.
The sections read name no assistant tier, no technician registration, and no sentence barring unlicensed practice; the Board's page does not mention behavior analysts, so confirm implementation before applying.
Verify before you rely on this
At a glance
One licence, behavior analyst: D.C. Code §3-1207.71, added July 19, 2024, directs the Board of Psychology to license qualifying applicants.
No assistant licence and no technician registration appear in the sections read.
The DC Board of Psychology, under DC Health.
The Board's psychology-licensing page, as of September 2026, does not mention behavior analysts.
Yes.
Current certification issued by the Behavior Analyst Certification Board is a statutory qualification, listed alongside the criminal background check and the degree clause.
None found in the sections read.
The statute names no BCaBA-level or assistant licence.
None found in the sections read: no technician registration, and no exemption written for behavior-analysis technicians; only the chapter's general §3-1205.02 health-occupations exemptions (emergencies, federal employees, some out-of-state practitioners) were found.
Not stated in the sources read: the sections read contain no sentence barring unlicensed practice or protecting the title — only the licensure qualification and the practice definition.
D.C. Code §3-1207.71 (Subchapter VII-G), as added July 19, 2024 by D.C. Law 25-191, § 101(hhh); the practice definition sits at §3-1201.02(2C-i).
The Washington, DC credential ladder
- Behavior analyst (licensed)Independent
The only credential the sections read name: the Board of Psychology "shall license as a behavior analyst" an applicant who completes the criminal background check, holds current BACB certification and meets the degree clause of D.C. Code §3-1207.71, with the degree clause waived for anyone BACB-certified on or before July 19, 2024.
One licence, granted by the Board of Psychology
DC's 2024 law creates a single credential: the Board of Psychology shall license as a behavior analyst whoever meets §3-1207.71.
No assistant licence, no technician registration and no pre-licensure status appear in the sections read, so a BCaBA, an RBT or a supervised fieldwork trainee holds no DC credential named in the sources read.
The saved statute heads the section 'Eligibility requirements and education', and the definition of the practice sits with the chapter's definitions at §3-1201.02(2C-i).
For how BACB certification and a state licence fit together, see BACB certification vs. state behavior analyst licensure.
“The Board of Psychology shall license as a behavior analyst a person who, in addition to meeting the requirements of subchapter V of this chapter and any requirements the Mayor may establish by rule, has: (1) Successfully completed a criminal background check; (2) Obtained a current certification issued by the Behavior Analyst Certification Board; and (3) Received a master's degree or higher from a behavior analysis educational program that is accredited by the Behavior Analyst Certification Board; provided, that the Board shall waive this educational requirement if the applicant was certified by the Behavior Analyst Certification Board on or before July 19, 2024.”
The route: BACB certification, a degree clause and a 2024 waiver
Clause (2) makes current BACB certification a qualification the statute names for the licence, so an application runs through the national credential.
Clause (3) then requires a master's degree or higher from a behavior analysis educational program 'accredited by the Behavior Analyst Certification Board' — wording with no settled application, because the BACB certifies practitioners and does not accredit degree programs (ABAI and APBA accredit those), and how the Board will apply the clause is not stated in the sources read; do not assume an ABAI-accredited master's satisfies it until the Board says so.
The proviso waives the degree clause for anyone BACB-certified on or before July 19, 2024, which covers the pre-law workforce.
Every applicant must also meet subchapter V's requirements and any requirements the Mayor establishes by rule; Mayor rules were not in the sources read, so fees, applications and any DC-specific additions are unknown.
The BACB’s own degree, coursework, fieldwork and exam requirements are covered in how to become a BCBA.
What the practice of behavior analysis covers
The chapter defines the licensed work functionally: designing, implementing and evaluating environmental modifications to produce socially significant improvement in human behavior, with direct observation, measurement and functional analysis named as part of the practice.
The sections read add nothing beyond the definition — no scope exclusions, no delegation rules and no exemption specific to behavior analysis.
The only exemptions in view are §3-1205.02's general health-occupations ones (emergencies, federal employees, some out-of-state practitioners), so a psychologist, a teacher or a school staffer in DC has no behavior-analysis exemption named in the sources read.
“'Practice of behavior analysis' means the design, implementation, and evaluation of environmental modifications to produce socially significant improvement in human behavior, including the use of direct observation, measurement, and functional analysis of the relationship between environment and behavior.”
A 2024 law, with implementation still to confirm
The whole provision is new: the section credit shows it was added July 19, 2024 by D.C. Law 25-191, § 101(hhh).
The same date anchors the degree waiver, so certificants of July 19, 2024 or earlier keep the grandfather path.
What the sources do not establish is any date on which the licence became mandatory or applications opened — the sections read carry no implementation date.
Treat July 19, 2024 as the date the section was added, not as a confirmed first day of licensure.
“( Mar. 25, 1986, D.C. Law 6-99, § 771 ; as added July 19, 2024, D.C. Law 25-191, § 101(hhh), 71 DCR 6698 .)”
Is the licence being issued? What the sources could not verify
The statute text is verified against the D.C. Council's published code, but whether the Board is actually issuing licences is a separate question the sources read could not settle.
The Board of Psychology's page on DC Health, as of September 2026, does not mention behavior analysts, and the sources could not establish whether the Board has begun issuing behavior-analyst licences, how the BACB-accreditation clause will be applied, or any assistant or technician rules.
For a BCBA weighing a DC move, that means the law is on the books but the practical path — application, fees, any Mayor rule — is not yet documented in anything this page can cite.
Contact the Board through the DC Health psychology-licensing page before you rely on the licence existing.
What This Page Does — and Doesn’t — Cover
This page summarizes the Washington, DC 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 District of Columbia Board of Psychology 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 District of Columbia Board of Psychology before you count hours, register for an exam or apply — and before you take one of the board certified behavior analyst jobs that asks for it.
Frequently Asked Questions
Do I need a DC license if I already hold BCBA certification?
The statute creates a licence that current BACB certification qualifies you for, not a certification that replaces it.
D.C. Code §3-1207.71 directs the Board of Psychology to license a person who completes a criminal background check, holds current BACB certification and meets the degree clause.
Whether DC bars unlicensed practice or use of the title is not stated in the sections read.
Implementation is a separate unknown — the Board's DC Health page did not mention behavior analysts as of September 2026 — so confirm with the Board before you advertise under a DC licence.
I was certified by the BACB before July 19, 2024. Do I still need the degree?
No. Section 3-1207.71's proviso says the Board 'shall waive this educational requirement if the applicant was certified by the Behavior Analyst Certification Board on or before July 19, 2024.'
You would still owe the criminal background check, current BACB certification, and whatever subchapter V and Mayor rules add.
If you certified after that date, the master's-or-higher degree clause applies as written — subject to the open question of how the Board applies the accreditation wording.
My master's is ABAI-accredited. Does that satisfy the degree clause?
The sources read cannot say.
The statute requires a program 'accredited by the Behavior Analyst Certification Board', but the BACB certifies individuals and does not accredit degree programs — ABAI and APBA do — and how clause (3) will be applied is not settled in the sources read.
An ABAI-accredited degree is a strong credential for BACB certification, but whether it satisfies §3-1207.71(3) is a question only the Board can answer.
Do RBTs or behavior technicians need a DC credential?
None is named in the sources read: the sections read found no technician registration and no exemption written for behavior-analysis technicians.
None found is not proof of absence — the Mayor's rules were not among the documents read — so confirm with the Board whether anything applies to technicians.
Employers, funders and payers can also set their own requirements, so verify with any employer before working as a technician in DC.
How do I check whether DC is issuing behavior analyst licenses yet?
Start with the DC Health psychology-licensing page, the Board of Psychology's home on the DC Health site; as of September 2026 it did not mention behavior analysts.
The DC Health-wide credential search is the other checkpoint: if the Board issues behavior analyst licences, they should appear there.
Neither source proves the licence is operational, so contact the Board directly before you apply.
More Washington, DC & Board Certified Behavior Analyst Resources
Sources
- D.C. Code § 3-1207.71 and § 3-1201.02(2C-i), Council of the District of Columbia Code (retrieved 2026-09-24)
- DC Health — Psychology Licensing (DC Board of Psychology) (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 District of Columbia Board of Psychology.