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ABA licensure by state

ABA licensure in Vermont: who needs a license, how to get one and how to keep it

The short answer

Vermont requires a state license to practice applied behavior analysis unless an exception in chapter 95 applies. The state licenses applied behavior analysts and assistant behavior analysts through the Office of Professional Regulation (OPR). Section 4904 provides exceptions for specified school work, supervised student training and certain customary duties.

Confirm with the Vermont Office of Professional Regulation before you rely on this.

What the law says

Vermont's law is Title 26, chapter 95 of the Vermont Statutes, "Applied Behavior Analysis." The first section sets the rule:

"In order to safeguard the life and health of the people of this State, a person shall not hold himself or herself out as practicing, practice, or offer to practice, as an applied behavior analyst or an assistant behavior analyst unless currently licensed under this chapter."

The chapter defines the two titles and the licensing office:

"“Applied behavior analyst” means a person who is licensed under this chapter to engage in the practice of applied behavior analysis."

"“Assistant behavior analyst” means a person who is licensed under this chapter to engage in the practice of applied behavior analysis under the supervision of an applied behavior analyst."

"“Director” means the Director of the Office of Professional Regulation."

Section 4903 lists violations. They include practicing without a license, using a title that implies a license, and an employer's use of unlicensed staff. The list says it is a violation to:

"employ an unlicensed or unauthorized person to practice as an applied behavior analyst or assistant behavior analyst"

"Any person violating this section shall be subject to the penalties provided in 3 V.S.A. § 127."

Section 4904 lists who the chapter does not prohibit. The first item covers a person who is not licensed, "who does not use the term “behavior analysis” or similar descriptors suggesting licensure under this chapter, and who is engaged in the course of his or her customary duties" in the settings it lists, such as work as an employee of or under contract with the Agency of Human Services, or work incident to another legally recognized profession. Two other items apply to students and to schools:

"A person engaged or acting in the discharge of his or her duties as a student of applied behavior analysis or preparing for the practice of applied behavior analysis, provided that the person’s title indicates his or her training status and that the preparation occurs under the supervision of an applied behavior analyst in a recognized training institution or facility."

"A behavior interventionist or paraprofessional, employed by a school, from working under the close direction of a supervisor licensed under this chapter, in relation to the direct implementation of skill-acquisition and behavior-modification plans developed by the supervisor or in relation to data collection or assessment designed by the supervisor, provided the supervisor retains ultimate responsibility for delegating professional responsibilities in a manner consistent with 3 V.S.A. § 129a(a)(6)."

Licensed practice is tied to a referral and has limits:

"A person licensed under this chapter shall only engage in the practice of applied behavior analysis upon, and within the scope of, a referral from a licensed health professional or school official duly authorized to make such a referral."

"The practice of applied behavior analysis shall not include psychological testing, neuropsychology, diagnosis of mental health or developmental conditions, psychotherapy, cognitive therapy, sex therapy, psychoanalysis, psychopharmacological recommendations, hypnotherapy, or academic teaching by college or university faculty."

Source: 26 V.S.A. chapter 95, Applied Behavior Analysis, sections 4901, 4902, 4903, 4904 and 4928.

How to get licensed

For an applied behavior analyst, the statute sets three requirements for licensure by examination:

"Obtain a doctoral or master’s degree from a recognized educational program accredited by the Association for Behavior Analysis International Accreditation Board, or from a program at a recognized educational institution that is approved by the Director and that substantially meets the educational standards of the Association for Behavior Analysis International Accreditation Board or the Behavior Analysis Certification Board."

"Successfully complete an approved practicum or supervised experience in the practice of applied behavior analysis, totaling at least 1,500 hours over a period of not less than one calendar year, of which at least 75 hours are in direct one-to-one contact with a supervisor."

"Successfully complete, as defined by the Director, a nationally recognized examination adopted from the Behavior Analyst Certification Board and approved by the Director, related to the principles and practice of applied behavior analysis."

The statute adds that "Any program shall include an approved course sequence of the Behavior Analyst Certification Board." Vermont also licenses by endorsement. Under section 4923, an applicant must either hold a qualifying registration or license from another U.S. jurisdiction or be certified as a board certified behavior analyst by the Behavior Analyst Certification Board. In either case, the applicant must meet any active practice requirements established by the Director by rule.

OPR's application instructions (February 2026) say applications go through its Online Services System, with a non-refundable application fee. An applicant by examination sends "a copy of your BCBA or BCBA-D certification from the Behavior Analyst Certification Board" or, instead, official transcripts and proof of the supervised experience and exam. OPR also has a fast-track path:

"To qualify to be licensed, an applicant must be actively licensed or certified in good standing in another jurisdiction for three or more years preceding this application."

For endorsement and fast track, OPR says an applicant whose only missing item is the other state's license verification "may indicate within the application that you would like to be issued a 90-day provisional license while the Office awaits receipt of your license verification."

Source: 26 V.S.A. 4921 and 4923; OPR, Applied Behavior Analyst Application Instructions, February 2026; OPR, Applied Behavior Analysis forms and instructions.

Assistants, RBTs and technicians

Vermont licenses assistant behavior analysts. Their requirements by examination include a bachelor's degree from an approved program, an approved practicum or supervised experience totaling at least 1,000 hours over at least one calendar year, and an approved examination.

An assistant works under supervision, and the statute sets a minimum:

"An assistant behavior analyst shall only engage in the practice of applied behavior analysis if he or she has a minimum of five hours per month of off-site case supervision by an applied behavior analyst."

The same section says a supervising analyst "may require that his or her supervision of an assistant behavior analyst exceed the minimum requirements of this section, including the requirement that the supervision be on-site."

We did not find registered behavior technicians, RBTs or similar titles named in chapter 95. The only provision for technician-level staff we found is the school exemption quoted above, for a school-employed "behavior interventionist or paraprofessional" working under the close direction of a licensed supervisor. For technicians outside schools, ask OPR how it applies the chapter.

Source: 26 V.S.A. 4922 and 4929; 26 V.S.A. 4904.

Renewal and state-required training

Licenses renew on a two-year cycle:

"Licenses shall be renewed every two years, on a schedule determined by the Director, upon payment of the renewal fee."

The law lets the Director require continuing education as a condition of renewal, and it names one required topic:

"The Director may accept proof of current certification from the Behavior Analyst Certification Board as evidence of continuing competency if the Director finds that the maintenance of such certification implies appropriate continuing education consistent with this subsection and Board rule."

"Continuing education requirements shall include requiring one or more continuing education units in the area of systematic oppression and anti-oppressive practice, or in related topic areas"

OPR's renewal instructions for applied behavior analysts (February 2026) say renewal applications "open six weeks before the expiration date" and are submitted through the Online Services System. To renew, you upload two items. One is:

"completion certificate showing a minimum of 1 credit of completed continuing education related to systematic oppression and anti-oppressive practice or related areas."

The other is:

"a copy of your current BCBA or BCBA-D certification from the Behavior Analyst Certification Board."

The renewal instructions also say "Late renewals are subject to penalties." The statute says "Synchronous virtual continuing education credits shall be approvable and accepted as live in-person training."

Source: 26 V.S.A. 4925; OPR, Applied Behavior Analyst Renewal Instructions, February 2026.

Training the staff you supervise

If you run a program in Vermont and need new technicians or aides trained in the basics, this is what our Intro to ABA Level 1 course covers.

The Intro to ABA Level 1 course teaches methods and techniques of Applied Behavior Analysis (ABA) for parents and caregivers, teachers, paraprofessionals and behavior technicians who work with a child every day. Topics include what autism is, what ABA is, pairing, errorless teaching and prompting, and active student responding. Complete the course and pass its 40-question final exam with a score of at least 80%. Completing this course earns a Special Learning certificate of completion. That certificate is not a continuing education (CE) certificate. It is basic training in ABA methods for daily practice, not a professional credential. It is not the 40-hour training required for the RBT credential. We do not claim Vermont state approval or continuing education credit for this course.

Two ways to start

Last reviewed: October 30, 2026.

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