ABA licensure in Virginia: who needs a license, how to get one and how to keep it
The short answer
Virginia generally requires a Board of Medicine license to practice as a behavior analyst or assistant behavior analyst, subject to statutory exemptions. Applicants must hold current Behavior Analyst Certification Board (BACB) certification as a BCBA for behavior analyst licensure or a BCaBA for assistant behavior analyst licensure. Active licenses renew every two years, in odd-numbered years during the licensee's birth month. The standard continuing education requirement per biennium is 32 hours for behavior analysts or 20 for assistants, including four ethics hours; the first biennial renewal after initial Virginia licensure is exempt from continuing education.
Confirm with the Virginia Board of Medicine before you rely on this.
What the law says
Virginia licenses behavior analysts and assistant behavior analysts under Title 54.1, Chapter 29 of the Code of Virginia. The Board of Medicine issues the licenses. The statute says:
"It is unlawful for any person to practice or to hold himself out as practicing as a behavior analyst or to use the title "Licensed Behavior Analyst" unless he holds a license as a behavior analyst issued by the Board. It is unlawful for any person to practice or to hold himself out as practicing as an assistant behavior analyst or to use the title "Licensed Assistant Behavior Analyst" unless he holds a license as an assistant behavior analyst issued by the Board."
The Code defines the practice of behavior analysis as:
"the design, implementation, and evaluation of environmental modifications, using behavioral stimuli and consequences, 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."
Who is exempt. The Code lists four groups. In summary: other licensed, certified or registered health professionals acting within their own scope of practice; students participating in a defined course, internship, practicum or program of study at a higher education institution, whose activities are supervised by an institutional faculty member or licensed behavior analyst, who do not hold themselves out as licensed behavior analysts, and who are identified as a "behavior analyst student," "behavior analyst intern," or "behavior analyst trainee"; unlicensed people doing supervised experiential training for BACB certification or state licensure; and employees of a school board or of a school for students with disabilities licensed by the Board of Education. The supervised-training and school-employee conditions are quoted below. On supervised training it says:
"The provisions of § 54.1-2957.16 shall not be construed as prohibiting or restricting the activities of unlicensed individuals pursuing supervised experiential training to meet eligibility requirements for certification by the Behavior Analyst Certification Board or for state licensure, provided such activities are supervised by a licensed behavior analyst who has been approved by the Behavior Analyst Certification Board to provide supervision, the individual does not hold himself out as a licensed behavior analyst, and no more than five years have elapsed from the date on which the supervised experiential training began."
On school employees it says:
"The provisions of § 54.1-2957.16 shall not be construed as prohibiting or restricting the activities of an individual employed by a school board or by a school for students with disabilities licensed by the Board of Education from providing behavior analysis when such behavior analysis is performed as part of the regular duties of his office or position and he receives no compensation in excess of the compensation he regularly receives for the performance of the duties of his office or position."
The same subsection adds: "No person exempted from licensure pursuant to this subsection shall hold himself out as a licensed behavior analyst or a licensed assistant behavior analyst unless he holds a license as such issued by the Board."
Source: Va. Code § 54.1-2957.16; Va. Code § 54.1-2957.17; Va. Code § 54.1-2900.
How to get licensed
The Board's regulation, 18VAC85-150-60, ties licensure to BACB certification:
"An applicant for licensure to practice as a behavior analyst or an assistant behavior analyst shall hold current certification as a BCBA® or a BCaBA® obtained by meeting qualifications and passage of the examination required for certification as a BCBA® or a BCaBA® by the BACB."
An applicant for initial licensure submits, on the Board's forms: a completed application and fee; verification of that certification; verification of practice as the application form requires; if licensed or certified in another jurisdiction, verification that no disciplinary action has been taken or is pending there; and verification from the BACB on any disciplinary action taken or pending by that body (18VAC85-150-50). The statute also asks for documentation that the applicant "conducts his professional practice in accordance with the Behavior Analyst Certification Board ethics code for behavior analysts and any other accepted professional and ethical standards the Board deems necessary".
A person who holds a current, active license in good standing in another United States jurisdiction or Canada may apply by endorsement. The regulation lists the current license, a completed application and fee, the BACB certification verification, and "A current report from the National Practitioner Data Bank" (18VAC85-150-51).
Fees are set in 18VAC85-150-40. It says: "The initial fee for the behavior analyst license shall be $130; for the assistant behavior analyst license, it shall be $70."
Source: 18VAC85-150-60; 18VAC85-150-50; 18VAC85-150-51; 18VAC85-150-40; Va. Code § 54.1-2957.16. Applications go through the Virginia Board of Medicine.
Assistants, RBTs and technicians
Assistant behavior analysts are licensed. The applicant must hold BCaBA certification and must provide:
"Documentation that the applicant's work is supervised by a licensed behavior analyst in accordance with the supervision requirements and procedures established by the Board."
The regulation requires a written supervisory agreement between the licensed behavior analyst and the licensed assistant behavior analyst, covering the domains of competency in which the assistant may provide services and the nature and frequency of supervision. It adds that supervision interactions "shall occur not less than once every four weeks with each supervision session lasting no less than one hour" (18VAC85-150-120).
Registered Behavior Technicians and other technicians are not a licensed category in the Virginia sections we read. The regulation speaks of "unlicensed personnel." It says they may be supervised by a licensed behavior analyst or a licensed assistant behavior analyst, and may be used for:
"Nonclient-related tasks, including but not limited to clerical and maintenance activities and the preparation of the work area and equipment; and"
"Certain routine client-related tasks that, in the opinion of and under the supervision of a licensed behavior analyst or a licensed assistant behavior analyst, have no potential to adversely impact the client or the client's treatment plan and do not constitute the practice of behavior analysis."
Source: Va. Code § 54.1-2957.16; 18VAC85-150-120; 18VAC85-150-130.
Renewal and state-required training
Renewal is in the licensee's birth month in each odd-numbered year (18VAC85-150-70):
"Every behavior analyst or assistant behavior analyst who intends to maintain an active license shall biennially renew his license each odd-numbered year during his birth month and shall:"
The licensee submits the renewal fee and attests to having met the continuing education requirements. A license not renewed by the first day of the month after the month in which renewal is required "is lapsed."
The continuing education rule, 18VAC85-150-100, says:
"In order to renew an active license, a behavior analyst shall attest to having completed 32 hours of continuing education and an assistant behavior analyst shall attest to having completed 20 hours of continuing education as approved and documented by a sponsor recognized by the BACB within the last biennium. Four of the required hours shall be related to ethics in the practice of behavior analysis."
That rule also provides that up to two hours may be satisfied through unpaid services to low-income individuals through a local health department or free clinic, that a practitioner is exempt from continuing education for the first biennial renewal after initial licensure in Virginia, that records are kept for four years after renewal, and that the Board audits randomly. These are the Board's rules. The sections we read name ethics as the one required topic.
Source: 18VAC85-150-70; 18VAC85-150-100.
Training the staff you supervise
If you run a program in Virginia 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 Virginia state approval or continuing education credit for this course.
Two ways to start
- For one person: try the first two sessions free for 7 days; account creation is required, with no payment information requested. The full course costs $199, paid once, with no subscription or recurring charge. Activate your license code within 90 days of purchase; the published completion window is 10 weeks after activation. You may request a later start date, no later than three months after purchase. Start the free sessions
- For your team: tell us how many people need training and when, and we will send a quote; each participant who completes the course and passes its 40-question final exam with a score of at least 80% earns an individual certificate of completion. Ask for a team quote
Last reviewed: October 30, 2026.
See every state's ABA licensure rules
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Notes for the build (not page copy):
- Sub-agent draft for Hana (FABLE-GMAIL), October 30, 2026. Sources and verbatim text: VA-SOURCES.txt beside this file. Fetched with curl from law.lis.virginia.gov (the Virginia General Assembly's official Code and Administrative Code site) and dhp.virginia.gov, because WebFetch returns a model summary, not verbatim text.
- slug: guides/aba-licensure/virginia
- crumb: Virginia
- title: Virginia ABA Licensure: Rules for BCBAs | Special Learning
- faq_q: Do you need a license to practice ABA in Virginia?
- license: yes
- title_held: Licensed Behavior Analyst, Licensed Assistant Behavior Analyst (the statute does not use an abbreviation)
- agency: Virginia Board of Medicine (Department of Health Professions), with its Advisory Board on Behavior Analysis
- renewal: Every 2 years (odd-numbered years, birth month); 32 CE hours (BA) or 20 (assistant), 4 in ethics
- Uncertainty: the regulation was amended in Register Vol. 42, Issue 6, effective December 3, 2025 (sections 50, 51, 60). The page quotes the text as the site showed it on October 30, 2026. Section 54.1-2957.18 (Advisory Board) shows a 2026 amendment (2026, c. 618); the page does not describe the Advisory Board's composition.
- Uncertainty: the Board's own pages (dhp.virginia.gov/Boards/Medicine) did not give a behavior-analysis-specific page we could read; the Board's forms and fee page were not read. Fees are quoted from 18VAC85-150-40 only. The 2026 General Assembly session may have changed behavior analyst law elsewhere in Title 54.1; only sections 54.1-2957.16 to .18 and 54.1-2900 were read.
- Uncertainty: the Board's human trafficking continuing education notice on its home page was not checked against behavior analysts; 18VAC85-150-100 as read does not mention it.
- The page does not say how many RBTs there are or how Virginia treats them beyond "unlicensed personnel" in 18VAC85-150-130.
- Reader r1 (both items applied): short answer replaced with the reader's text (exemptions and first-renewal CE exemption now stated; first sentence stands alone); student exemption now carries its supervision, no-holding-out and title conditions per 54.1-2957.17(B), and "For the last two groups" replaced with "The supervised-training and school-employee conditions are quoted below." The exemption quotes are from 54.1-2957.17 (verbatim in VA-SOURCES.txt); the page's Source line for that paragraph already lists it.
