What changes in the 2027 BCBA fieldwork requirements?

Three things change on January 1, 2027: the monthly maximum rises from 130 to 160 hours, concentrated fieldwork supervision drops from 10% to 7.5%, and client observations shift from one contact per month to a duration minimum of 60 minutes per month for supervised fieldwork and 90 for concentrated. The totals (2,000 supervised or 1,500 concentrated), the 5% supervision rate for supervised fieldwork, and the 60% unrestricted requirement do not change.

Do the 2027 BCBA rules apply to me?

It depends on your application date, not when you started fieldwork. If you submit a complete application and meet the current requirements before January 1, 2027, the 2022 rules apply. If you apply on or after that date, you must meet the 2027 requirements. Pathways 3 and 4 also disappear on that date.

Do hours logged under the 2022 rules count under the 2027 rules?

Mostly yes, because the 2022 rules are stricter where it matters: concentrated hours supervised at 10% clear the 7.5% bar, and months capped at 130 hours fit inside the 160-hour cap. The reverse is not true: 7.5% concentrated months and 160-hour months do not back-count under the 2022 rules, and contact-based observations may not meet the new duration minimums.

BCBA Fieldwork Requirements: 2022 vs 2027

The BACB's new eligibility requirements take effect on January 1, 2027, and the rule that decides everything is the application date, not when you started fieldwork: if you submit a complete application and meet the current requirements before that date, the 2022 rules apply; apply on or after it and the 2027 rules do. Everything below comes from the BACB's own 2027 requirements and transition guidance, current as of their January 2026 update; the BACB documents are always the final word.

What actually changes on January 1, 2027

Less than the forum panic suggests. The totals stay the same, the 60% unrestricted requirement stays the same, and supervised fieldwork keeps its 5% supervision rate. Three things move, shown here per fieldwork type with changes marked:

Supervised fieldwork

Requirement	2022 rules	2027 rules
Total hours	2,000	2,000
Supervision	5% of hours	5% of hours
Hours per month	20 to 130	20 to 160
Client observations	One per month	60 minutes per month

Concentrated fieldwork

Requirement	2022 rules	2027 rules
Total hours	1,500	1,500
Supervision	10% of hours	7.5% of hours
Hours per month	20 to 130	20 to 160
Client observations	One per month	90 minutes per month

In the BACB's words, observation tracking shifts from contact-focused to duration-focused. One quick observation used to satisfy the month; from 2027 the minutes are what count.

Which rule set applies to you?

Only the application date decides. Three situations:

Finishing and applying before January 1, 2027: the 2022 rules apply, log against them and use the 2022 verification forms.
Starting in 2026 or later with an application after the deadline: the 2027 rules apply to your whole application, including hours you accrued before 2027.
Unsure which side of the deadline you land on: this is the group the transition punishes, and the next section is for you.

Also on January 1, 2027: eligibility pathways 3 and 4 disappear. If you planned to apply under either, the complete application has to be in, and the requirements met, before that date.

The traps in the transition

The 2022 rules are stricter where it matters, so hours logged under them mostly carry forward. The reverse direction is where months get lost:

Concentrated supervision. Months supervised at 7.5% under the 2027 rules cannot count as concentrated fieldwork under the 2022 rules, which require 10%. Months at 10% count under both.
The monthly cap. A 160-hour month is valid under the 2027 rules but over the 2022 cap of 130. Months at or under 130 fit both.
Observations. A single short contact satisfies the 2022 rules but may miss the 2027 duration minimums. An observation that is both a real contact and at least 60 or 90 minutes satisfies both.
The forms. Your monthly verification forms (M-FVFs) must match the rule set you eventually apply under. The BACB's own recommendation for the unsure: complete both the 2022 and 2027 forms every month, and keep all fieldwork documentation for at least 7 years.

Put together, the safe play if you are unsure when you will apply: supervise concentrated fieldwork at 10%, stay at or under 130 hours per month, make observations that clear both the contact and the minutes bar, and sign both form sets monthly. You will be eligible under whichever rules apply when you get there.

How Hourcrest handles both rule sets

This transition is exactly why Hourcrest tracks the rule, not the total: every constraint above gets its own meter, checked against the 2022 rules, the 2027 rules, or both at once if you are in the unsure group. Your supervisor signs each month from an email link, so the record the BACB can request for 7 years is signed, sealed, and exportable, not a spreadsheet you hope agrees with your forms. The BCBA fieldwork tracker page has the details.