Maryland Emergency Teacher Certification Requirements

Maryland does not use the term ’emergency teacher certificate’ in its current regulatory framework. What other states call emergency certification, Maryland addresses through a system of four distinct non-standard or provisional license types: the Conditional License, the Conditional Special Education License, the Temporary Professional Teacher License, and the Adjunct Teacher License.

Each is designed for a specific set of circumstances where a fully certified teacher is unavailable, and each carries its own eligibility requirements, validity period, and restrictions.

This is an important distinction for anyone researching Maryland teacher certification: if you are searching for a Maryland emergency teacher certificate, you are most likely looking for one of these four non-standard license types — primarily the Conditional License, which is Maryland’s broadest and most commonly issued stopgap teaching credential.

The Conditional License is the instrument Maryland school systems use when they cannot fill a position with a fully qualified, professionally licensed teacher.

The regulatory foundation for all four non-standard licenses is COMAR Title 13A, Subtitle 12, Section 13A.12.02 — Maryland’s comprehensive educator licensure regulation.

The most significant recent development is the April 1, 2024 overhaul of COMAR 13A.12, which extended the Conditional License validity period from the former 2-year duration to a maximum of 5 years under the new regulatory framework, and renamed the former Conditional Certificate to Conditional License throughout.

Understanding both the old and new frameworks is essential because many practitioners and districts still reference the old terminology.

In 2021-22, Maryland had 1,616 unfilled teaching positions and 6,724 teachers considered underqualified — many of them in conditional or temporary teaching roles. These numbers underscore why Maryland’s non-standard licensing framework matters: it is not theoretical; it is the daily operational reality of Maryland’s 24 local education agencies and Baltimore City Public Schools.

Key Clarification: Maryland’s Non-Standard Teaching Licenses at a Glance

THERE IS NO ‘EMERGENCY CERTIFICATE’ IN MARYLAND: Maryland does not issue a credential specifically labeled ’emergency certificate.’ Instead, it issues four types of non-standard licenses for situations where a fully certified teacher is unavailable.

LICENSE TYPE 1 — CONDITIONAL LICENSE (CL): The primary non-standard teaching license. Valid up to 5 years (non-renewable). School system must request it. Requires bachelor’s degree. Candidate must pursue pathway to professional licensure.

LICENSE TYPE 2 — CONDITIONAL SPECIAL EDUCATION LICENSE: Specifically for special education vacancies. Valid 3 years (non-renewable). Additional IDEA-driven requirements apply.

LICENSE TYPE 3 — TEMPORARY PROFESSIONAL TEACHER LICENSE: For out-of-state licensed teachers or those who failed to meet renewal requirements. Valid 2 years (non-renewable). More limited scope.

LICENSE TYPE 4 — ADJUNCT TEACHER LICENSE: For content area experts without formal teacher preparation. Valid 1 year, renewable. Limited to specific teaching contexts.

All issued by MSDE at the request of a local school system, State-operated school, or approved nonpublic school — not applied for by the candidate independently.

Sources: COMAR 13A.12.02.02 (regs.maryland.gov; law.cornell.edu/regulations/maryland); MSDE Educator Licensure Overview (April 1, 2024); MSEA Certificate-to-License Conversion chart (May 2024).

Maryland Emergency/Non-Standard Teacher Licenses: Key Numbers

Non-Standard License Types

Conditional, Cond. SpEd, Temp. Prof., Adjunct

5 yrs

Conditional License Validity

COMAR 13A.12.02.02E(1) — non-renewable

3 yrs

Conditional SpEd Validity

COMAR 13A.12.02.02F(1) — non-renewable

2 yrs

Temporary Professional Validity

COMAR 13A.12.02.02A(1) — non-renewable

1 yr

Adjunct Teacher License

COMAR 13A.12.01.02 — renewable annually

BA Req.

Min. Degree (Most Types)

Bachelor’s degree — COMAR 13A.12.02.02

6,724

Underqualified Teachers (2021-22)

MSDE/NCES; emergency cert demand

Apr.24

Major Regulatory Overhaul

COMAR update; 2-yr CL→5-yr CL

Sources: COMAR 13A.12.02.02 (regs.maryland.gov/us/md/exec/comar/13A.12.02.02 and law.cornell.edu/regulations/maryland/COMAR-13A-12-02-02) — all validity periods; MSEA Certificate-to-License Conversion (tabco.org, May 2024) — Conditional License old 2-yr to new 5-yr; teachercertificationdegrees.com MD (March 2026) — 6,724 underqualified; MSDE Educator Licensure Overview Generic PDF (April 1, 2024).

Maryland’s Non-Standard License Framework: Legal Foundation

All non-standard teacher licensing in Maryland is governed by COMAR Title 13A (State Board of Education), Subtitle 12 (Educator Licensure), Chapter 13A.12.02 (Teachers). The specific provisions for each non-standard license type are codified in COMAR 13A.12.02.02 — Licenses for Teachers. This section of the Maryland Code of Regulations is the definitive primary source.

COMAR 13A.12.02.02: The Primary Statute

COMAR 13A.12.02.02, titled ‘Licenses for Teachers,’ is current through Register Vol. 52, No. 6, March 21, 2025 (per Justia Law). This regulation establishes all Maryland teacher license types — both professional and non-standard — including their validity periods, eligibility requirements, and the conditions under which each can be issued. The full text is available from two authoritative sources:

Maryland Department of State (official): regs.maryland.gov/us/md/exec/comar/13A.12.02.02
Cornell LII (authenticated copy): law.cornell.edu/regulations/maryland/COMAR-13A-12-02-02
Justia Law (current through March 21, 2025): regulations.justia.com/states/maryland/title-13a/subtitle-12/chapter-13a-12-02/section-13a-12-02-02

Supporting COMAR Provisions

COMAR 13A.12.01.02 — Definitions: Defines ‘Conditional License’ as ‘a non-renewable license issued while the applicant pursues a pathway to professional licensure’ (Justia Law, current through March 21, 2025).
COMAR 13A.12.02.04 — Renewal and Advancement: Establishes conditions under which a Temporary Professional License can be issued when a professional license holder fails to meet renewal requirements.
COMAR 13A.12.01 — General Provisions: Provides framework definitions and the general educator licensure structure; establishes that the Conditional License is ‘a nonrenewable license valid for a period not to exceed 5 years issued only for licenses under COMAR 13A.12.02.02A.’

Sources: regs.maryland.gov/us/md/exec/comar/13A.12.02.02 (primary Maryland regulatory database); law.cornell.edu/regulations/maryland/COMAR-13A-12-02-02 (Cornell LII); regulations.justia.com (current through March 21, 2025); marylandpublicschools.org (MSDE COMAR references).

The April 1, 2024 Regulatory Overhaul

Effective April 1, 2024, Maryland implemented the most comprehensive update to its educator licensure regulations in years under new COMAR 13A.12 regulations. The changes most relevant to non-standard and emergency-type certification are:

Certificate to License Conversion

Every Maryland educator credential type was renamed from ‘certificate’ to ‘license.’ This is not merely cosmetic — the regulatory language throughout COMAR 13A.12 was updated, and the MSDE’s official documents now use license terminology exclusively. When people reference the old ‘Conditional Certificate’ or ‘Conditional Teacher Degree Certificate,’ they are referring to what is now called the Conditional License.

Conditional License Validity Extended

Per the MSEA Certificate-to-License Conversion chart (May 2024, TABCO document): the Conditional License changed from a 2-year validity period (under the old ‘Conditional Certificate’ system) to ‘valid for a period not to exceed 5 years’ under the new COMAR 13A.12.02.02E.

This is a significant change — the COMAR 13A.12.01 General Provisions document confirms: ‘The Conditional License is a nonrenewable license valid for a period not to exceed 5 years issued only for licenses under COMAR 13A.12.02.02A.’

However, multiple sources — including teachercertificationdegrees.com MD Alternative (January 2026) and the older BTU/BCPSS Educator Licensure Overview — still reference a 2-year validity. The regulatory text is clear: the current 2025 COMAR establishes up to 5 years for the general Conditional License.

The 2-year figure may reflect either the old pre-April 2024 rule or specific local school system practice that is more restrictive than the regulatory maximum. Always verify with MSDE or your specific school system’s HR office.

⚠ Verify With Your School System: While COMAR 13A.12.02.02E establishes that the Conditional License ‘is valid for 5 years and may not be renewed,’ individual school systems may issue conditional licenses for shorter periods consistent with their operational needs. Confirm the specific validity period with your LEA’s licensure office and with MSDE at [email protected].

Non-Renewability Confirmed

The April 2024 overhaul clarified that Conditional Certificates may not be renewed under the new framework: ‘Conditional certificates may not be renewed after April 1, 2024, but local school systems (LSS) may request a Conditional License for an employee who has not yet met the requirements for professional licensure.’

This is important: if you held a Conditional Certificate before April 2024, it transitioned to the new license system but cannot be renewed as a Conditional License. School systems can, however, request a NEW Conditional License for an employee who still has not met requirements.

Sources: MSDE Educator Licensure Overview Generic PDF (marylandpublicschools.org, April 1, 2024); BTU/BCPSS Educator Licensure Overview (baltimoreteachers.org, June 2024); MSEA Certificate-to-License Conversion (tabco.org, May 2024); COMAR 13A.12.01 General Provisions.

The Complete Spectrum: All Four Non-Standard License Types

License Type	COMAR Authority	Validity	Renewable?	Who Requests It	Primary Purpose
Conditional License (CL)	13A.12.02.02E	Up to 5 years	Non-renewable	Local school system, State-operated school, or approved nonpublic school	Cannot fill position with qualified individual; candidate must have BA+; must pursue pathway to professional licensure
Conditional Special Education License	13A.12.02.02F	3 years	Non-renewable	Local school system, State-operated school, or approved nonpublic school	Cannot fill SpEd position; additional IDEA constraint: must demonstrate candidate is pursuing SpEd preparation program
Temporary Professional Teacher License	13A.12.02.02A	2 years	Non-renewable	Local school system, State-operated school, or approved nonpublic school	Out-of-state licensed teacher who hasn’t passed MD tests; OR professional license holder who failed to meet renewal requirements
Adjunct Teacher License	13A.12.02.02H	1 year	Renewable annually	Local school system superintendent or nonpublic school education director	Content area experts (not traditionally prepared); subject-matter instruction in specific content areas; specific documentation requirements

Sources: COMAR 13A.12.02.02 (regs.maryland.gov/us/md/exec/comar/13A.12.02.02) — all validity periods and renewal status; COMAR 13A.12.01 General Provisions; Cornell LII COMAR 13A.12.02.02; Justia Law (current March 21, 2025).

License Type 1: The Conditional License (CL)

The Conditional License is Maryland’s primary non-standard teaching credential — the closest equivalent to what other states call an emergency or alternative teaching certificate. It is issued when a school cannot fill a position with a fully qualified professional license holder, and it provides temporary teaching authority while the candidate works toward full licensure.

COMAR 13A.12.02.02E — The Statutory Text

Per COMAR 13A.12.02.02E (regs.maryland.gov and law.cornell.edu, current through March 21, 2025):

E(1): ‘A conditional license is valid for 5 years and may not be renewed.’
E(2): ‘A local school system, State-operated school, or nonpublic school approved under COMAR 13A.09.10 shall request a conditional license only if the school cannot fill a position with an individual who qualifies for a license under Regulation .03 of this chapter.’
E(3): ‘A conditional license may only be issued to an individual who possesses a bachelor’s degree or higher.’
E(4): ‘An applicant who is issued a conditional license shall pursue a pathway to professional licensure under Regulation .03 of this chapter.’

Source: COMAR 13A.12.02.02E (regs.maryland.gov/us/md/exec/comar/13A.12.02.02; law.cornell.edu/regulations/maryland/COMAR-13A-12-02-02) — current through Register Vol. 52, No. 6, March 21, 2025.

What the Conditional License Authorizes

Teaching authority: The Conditional License authorizes the holder to serve as the teacher of record in the position for which it was issued — teaching their assigned students with full classroom responsibility.
Content area and grade level: The Conditional License is issued ‘in teaching areas only’ per the MSEA Conversion Chart — meaning it is specific to the teaching content area and grade level of the position being filled.
Specific school system: The Conditional License is tied to the requesting school system or school. It is not portable to other Maryland school systems.
Duration: Valid for up to 5 years per the current COMAR (though individual school systems may issue it for shorter periods).

Conditional License Eligibility Requirements in Detail

The eligibility requirements for the Conditional License are established in COMAR 13A.12.02.02E and confirmed by the MSEA Certificate-to-License Conversion chart and MSDE Licensure Overview.

Conditional License — All Eligibility Requirements (COMAR 13A.12.02.02E)

REQUIREMENT 1 — BACHELOR’S DEGREE: The candidate must possess a bachelor’s degree or higher from an accredited institution. COMAR 13A.12.02.02E(3): ‘A conditional license may only be issued to an individual who possesses a bachelor’s degree or higher.’ The MSEA Conversion Chart confirms: ‘Bachelor’s degree (unless in a Professional Technical Education area).’ NOTE: The PTE exception allows CTE candidates without a bachelor’s degree in some circumstances — see Section 5 of this guide.

REQUIREMENT 2 — SCHOOL SYSTEM CANNOT FILL THE POSITION: The requesting school system must certify that it cannot fill the position with a fully qualified individual. COMAR 13A.12.02.02E(2): the system ‘shall request a conditional license only if the school cannot fill a position with an individual who qualifies for a license under Regulation .03 of this chapter.’

REQUIREMENT 3 — SCHOOL SYSTEM MUST REQUEST IT: The Conditional License is issued ‘at the request of’ the employing school system. The candidate cannot apply independently — the LEA, State-operated school, or approved nonpublic school must initiate the request through MSDE.

REQUIREMENT 4 — MUST PURSUE PROFESSIONAL LICENSURE: COMAR E(4): ‘An applicant who is issued a conditional license shall pursue a pathway to professional licensure.’ This is a non-negotiable condition — the Conditional License is not a permanent credential and the holder must be actively working toward the IPL.

REQUIREMENT 5 — ASSESSMENT REQUIREMENTS: The candidate must obtain qualifying scores on a Department-approved test in basic skills (or 3.0 GPA exemption) and a qualifying score on a Department-approved content test. Per MSEA Conversion Chart: ‘Obtain qualifying score on a Department-approved test in basic skills or a comparable state-approved test in basic skills; Obtain a qualifying score on a Department-approved content knowledge area test.’

Sources: COMAR 13A.12.02.02E (regs.maryland.gov; law.cornell.edu); MSEA Certificate-to-License Conversion (tabco.org, May 2024).

The PTE (Professional/Technical Education) Exception

Per the MSEA Conversion Chart: the education requirement for the Conditional License is ‘Bachelor’s degree (unless in a Professional Technical Education area).’ This reflects COMAR’s allowance for CTE/vocational candidates who work in areas that do not require a bachelor’s degree.

Per the older COMAR 13A.12.01.08 text: ‘An applicant who does not possess a bachelor’s degree who is hired by a local school system in a career and technology education area which does not require a bachelor’s degree, and who does not meet the requirements for a professional certificate, may be issued the Conditional Teacher Nondegree Certificate at the request of the local superintendent of schools.’

Under the new framework, this becomes the Conditional License for PTE candidates without a bachelor’s degree. Contact MSDE at [email protected] to verify current rules for your specific PTE area.

Sources: MSEA Certificate-to-License Conversion Chart (tabco.org, May 2024); Sec. 13A.12.01.08 Conditional Certificate (mdrules.elaws.us) — historical PTE nondegree provision; COMAR 13A.12.02.02.

The ‘Cannot Fill a Position’ Requirement Explained

One of the most important practical constraints on the Conditional License is the requirement that the school system demonstrate it cannot fill the position with a fully qualified, professionally licensed teacher. This provision exists to ensure that the Conditional License is genuinely a gap-filler and not a mechanism for cost-cutting or bypassing qualified teachers.

What ‘Cannot Fill’ Means in Practice

Per COMAR 13A.12.02.02E(2), the school system ‘shall request a conditional license only if the school cannot fill a position with an individual who qualifies for a license under Regulation .03 of this chapter’ (Regulation .03 being the professional licensure standard). In practice, this means:

The school system has made reasonable attempts to recruit and hire a professionally licensed teacher for the position
No qualified, professionally licensed candidates are available for the specific position
The superintendent or designee makes this determination before submitting the conditional license request to MSDE
This is not merely a preference for a specific candidate — there must be an actual inability to fill the role with a certified teacher

Why This Requirement Matters

The ‘cannot fill’ requirement is a consumer protection for students and communities. Maryland’s Conditional License framework, unlike some states’ emergency certification systems, is specifically designed to prevent the routine use of underqualified teachers where qualified ones are available.

The National Council on Teacher Quality (NCTQ) has specifically cited this framework in its analysis of Maryland’s extended emergency licenses, noting that Maryland should ‘ensure that all teachers pass required subject-matter licensing tests before they enter the classroom’ and recommending limiting exceptions to one year — a standard Maryland has historically applied even if its 2024 regulatory update extended the maximum period to 5 years.

Sources: COMAR 13A.12.02.02E(2); NCTQ Yearbook: Extended Emergency Licenses: Maryland (nctq.org/yearbook/state/MD-Extended-Emergency-Licenses-73).

Conditional License and the Mandatory Pathway to Professional Licensure

The single most important obligation of a Conditional License holder — beyond the immediate teaching responsibilities — is the statutory requirement to pursue a pathway to professional licensure.

COMAR 13A.12.02.02E(4) states explicitly: ‘An applicant who is issued a conditional license shall pursue a pathway to professional licensure under Regulation .03 of this chapter.’ This is not aspirational language — it is a condition of the license.

Available Pathways to Professional Licensure for CL Holders

Per COMAR 13A.12.02 Regulation .03 (teacher professional licensure pathways), a Conditional License holder must pursue one of the following:

MAAPP/Resident Teacher License: Apply to a Maryland Approved Alternative Preparation Program (MAAPP) in partnership with the employing school system. This is the most common pathway — the school system that issued the Conditional License typically has or is affiliated with a MAAPP program.
University ACP or MAT Program: Enroll in a post-baccalaureate Alternative Certification Program or Master of Arts in Teaching (MAT) at a Maryland-approved institution (Johns Hopkins, Towson, University of Maryland, etc.).
Traditional Transcript Pathway (being eliminated): Note: the ‘transcript analysis or credit count pathway to licensure’ was eliminated on April 1, 2024, per the MSDE Licensure Overview. Individuals with certification evaluations issued before that date have until March 31, 2027 to complete that pathway.
Other approved pathways: In-district training programs (available from 2024-25 if district offers them); 5 years verified effective teaching experience at an approved Maryland nonpublic school; and other new flexible pathways introduced by the April 2024 reform.

Sources: MSDE Educator Licensure Overview (April 1, 2024) — elimination of transcript pathway; flexible new pathways; BTU/BCPSS Licensure Overview (June 2024); COMAR 13A.12.02.03 (professional licensure pathways).

MSDE Guidance for Conditionally Licensed Teachers

Per the MSDE Educator Licensure Overview: ‘Teachers employed with a conditional license in a Maryland local education agency, Maryland-operated school, or nonpublic special education school should contact their employer’s licensure office/point of contact for guidance on pathways to professional licensure.’

This makes the employer’s HR or licensure office the first point of contact — the school system that requested the Conditional License is also responsible for supporting the pathway to full licensure.

✔ Best Practice: Contact your school system’s HR or licensure office on Day 1 of your conditional license period to map out the exact pathway to your Initial Professional License. Ask specifically: Which MAAPP programs are available through your district? What courses are required? How will tuition and Praxis fees be covered? What is the timeline for completing all requirements within the 5-year (or shorter) conditional license period?

License Type 2: The Conditional Special Education License

The Conditional Special Education License is a distinct credential from the general Conditional License, with its own regulatory provisions, a shorter validity period, and additional requirements driven by federal IDEA mandates. It is codified in COMAR 13A.12.02.02F.

COMAR 13A.12.02.02F — Statutory Text

Per COMAR 13A.12.02.02F (Cornell LII and regs.maryland.gov, current March 2025):

F(1): ‘A conditional special education license is valid for 3 years and may not be renewed.’
F(2): ‘A local school system, State-operated school, or nonpublic school approved under COMAR 13A.09.10 shall request a conditional license only if: (a) The school cannot fill a special education position with an individual who qualifies for a license under Regulation .03 of this chapter; and…’
F(3): ‘A conditional license may only be issued to an individual who possesses a bachelor’s degree or higher.’
F(4): ‘An applicant who is issued a conditional license shall pursue a pathway to professional licensure under Regulation .03A(1) and (2) of this chapter.’

Source: COMAR 13A.12.02.02F (law.cornell.edu/regulations/maryland/COMAR-13A-12-02-02; regs.maryland.gov/us/md/exec/comar/13A.12.02.02) — current through March 21, 2025.

Key Differences from the General Conditional License

Feature	Conditional License (CL)	Conditional Special Education License
COMAR provision	13A.12.02.02E	13A.12.02.02F
Validity period	Up to 5 years	3 years (shorter)
Content area	Any teaching area	Special Education only
Pathway required	Regulation .03 (any professional pathway)	Regulation .03A(1) and (2) — more specifically SpEd preparation program pathway
Federal law constraints	None specific beyond COMAR	IDEA constrains; additional requirements apply
Shortage context	General staffing shortage	SpEd is the most critical shortage area in Maryland

The Critical IDEA Constraint on Conditional SpEd Licenses

Special education teacher certification carries federal constraints under the Individuals with Disabilities Education Act (IDEA) that do not apply to general education teacher credentials. These constraints are particularly important in the context of conditional or emergency-type credentialing for special education.

IDEA and Maryland Conditional SpEd Licenses — What You Need to Know

FEDERAL REQUIREMENT: Under IDEA Section 612(a)(14) and 34 C.F.R. § 300.156, each state must establish requirements for special education teacher preparation and qualifications. States may not waive these requirements — including through emergency or conditional certificates — in ways that undermine IDEA’s ‘highly qualified teacher’ standards.

MARYLAND’S APPROACH: The Conditional Special Education License allows school systems to employ a candidate in a SpEd position WHILE they complete preparation toward full SpEd licensure. The 3-year (not 5-year) validity period reflects the more constrained timeline IDEA effectively imposes.

REQUIREMENT THAT PATHWAY IS PURSUED: COMAR F(4) specifically requires the candidate to pursue ‘Regulation .03A(1) and (2)’ — the special education-specific preparation pathway — not just any general professional licensure pathway. This ensures the candidate is genuinely preparing to become a fully qualified SpEd teacher.

SCHOOL SYSTEM MUST CERTIFY POSITION UNFILLABLE: COMAR F(2)(a) requires the school to certify that it ‘cannot fill a special education position with an individual who qualifies for a license’ before requesting the conditional SpEd license. This cannot be used routinely to avoid hiring qualified SpEd teachers.

CONTRAST WITH SOME OTHER STATES: Some states have been cited for issuing emergency certificates for SpEd positions in ways that conflict with IDEA. Maryland’s separate Conditional SpEd License with its shorter validity and explicit SpEd-pathway requirement represents a more IDEA-conscious approach.

Sources: COMAR 13A.12.02.02F; IDEA Section 612(a)(14); 34 C.F.R. § 300.156; NCTQ analysis (nctq.org/yearbook/state/MD).

License Type 3: The Temporary Professional Teacher License

The Temporary Professional Teacher License is the most limited of Maryland’s four non-standard license types. Unlike the Conditional License (which is for unqualified candidates who need time to become qualified), the Temporary Professional is specifically designed for two narrow situations: out-of-state licensed teachers who haven’t yet passed Maryland tests, and professionally licensed Maryland teachers who failed to meet renewal requirements.

COMAR 13A.12.02.02A: Statutory Text

Per COMAR 13A.12.02.02A (Cornell LII, current March 2025):

A(1): ‘The Temporary Professional Teacher License is valid for 2 years and may not be renewed.’
A(2): ‘A local school system, State-operated school, or nonpublic school approved under COMAR 13A.09.10 may request a Temporary Professional License for an employee: (a) Who has completed an out-of-State teacher preparation program or holds a valid out-of-State professional license but has not submitted passing scores on Maryland teacher licensure tests; or (b) Who has failed to meet the renewal requirements of a professional license.’

Source: COMAR 13A.12.02.02A (law.cornell.edu/regulations/maryland/COMAR-13A-12-02-02) — current through March 21, 2025.

Who the Temporary Professional License Is For

Scenario A — Out-of-state teacher: You completed a teacher preparation program in another state or hold a valid out-of-state professional teaching license, but you have not yet passed the required Maryland Praxis content and/or assessment tests. The school system can request a Temporary Professional License while you complete Maryland’s testing requirements.
Scenario B — Renewal failure: You hold a Maryland Initial Professional, Professional, or Advanced Professional License but failed to complete the renewal requirements (90 PDPs and IPDP) before your license expired. Per COMAR 13A.12.02.04: ‘A local school system… may request a Temporary Professional License under Regulation .02A of this chapter for an employee who fails to meet the renewal requirements of the Initial Professional, Professional, or Advanced Professional license.’

In both scenarios, the Temporary Professional License provides a 2-year window to complete the outstanding requirement — Maryland testing in Scenario A, renewal requirements in Scenario B. After 2 years, the license expires and cannot be renewed.

Sources: COMAR 13A.12.02.02A; COMAR 13A.12.02.04 (Justia Law, current through September 20, 2024) — renewal failure scenario.

License Type 4: The Adjunct Teacher License

The Adjunct Teacher License is Maryland’s most distinctive non-standard license type, designed to bring content-area experts into classrooms in situations where their subject matter expertise is the primary qualification — not formal teacher preparation.

COMAR 13A.12.02.02H — Statutory Text

Per COMAR 13A.12.02.02H (Cornell LII, current March 2025):

H(1): ‘The Department may issue an adjunct license upon the request of a local school system superintendent or an education director of a nonpublic school approved under COMAR 13A.09.10.’
H(2): ‘The local school system superintendent or education director of the approved nonpublic school shall include with a request for an adjunct license.’

Per COMAR 13A.12.01 General Provisions: the Adjunct Teacher License is ‘a renewable license valid for a period not to exceed 1 year issued only for licenses under COMAR.’ This makes the Adjunct License unique among non-standard licenses — it is the only one that can be renewed, though it renews annually.

Key Characteristics of the Adjunct License

Annual renewable: Unlike other non-standard licenses, the Adjunct License renews on a year-by-year basis — the school system can request renewal annually for a content expert who continues to meet their specific needs.
Subject matter expert focus: The Adjunct License is for individuals who are recognized content-area experts but do not hold formal teacher preparation credentials. Examples: a professional historian teaching advanced history; an engineer teaching physics; a published author teaching creative writing.
Request documentation: The superintendent or nonpublic school director must include specific documentation with the adjunct license request to MSDE — typically demonstrating the candidate’s content expertise and the specific circumstances justifying the adjunct appointment.
Limited to specific teaching contexts: The Adjunct License is not a general teaching credential — it authorizes the specific teaching assignment for which it is requested.

Sources: COMAR 13A.12.02.02H (law.cornell.edu/regulations/maryland/COMAR-13A-12-02-02); COMAR 13A.12.01 General Provisions — ‘renewable license valid for period not to exceed 1 year.’

Assessment Requirements During Conditional Licensure

All Conditional License holders must meet Maryland’s standard assessment requirements as part of their pathway to professional licensure. The MSEA Conversion Chart explicitly lists assessment requirements for the Conditional License:

Obtain a qualifying score on a Department-approved test in basic skills OR a comparable state-approved test in basic skills (Praxis Core OR 3.0 GPA exemption)
Obtain a qualifying score on a Department-approved content knowledge area test (Praxis II Subject Assessment for the specific teaching area)

These are not simply future requirements to be met before receiving the IPL — they are conditions associated with the Conditional License.

Per the NCTQ analysis of Maryland, the framework contemplates that conditional license holders will pass required subject-matter tests; NCTQ has specifically noted the policy concern about ‘permitting individuals who have not yet passed state licensing tests to teach’ and has advocated for Maryland to ‘ensure that all teachers pass required subject-matter licensing tests before they enter the classroom.’

Sources: MSEA Certificate-to-License Conversion Chart (tabco.org, May 2024); NCTQ Yearbook Maryland Extended Emergency Licenses (nctq.org/yearbook/state/MD-Extended-Emergency-Licenses-73).

Basic Skills Assessment (Praxis Core or 3.0 GPA)

Option 1 — Praxis Core: Pass Praxis Core Academic Skills for Educators (Reading, Writing, Mathematics). Score sent to MSDE automatically if testing in Maryland or with Maryland profile address.
Option 2 — GPA exemption: Hold a minimum 3.0 GPA on the most recently earned degree. Conditional License holders who submit a transcript showing 3.0+ GPA are not required to submit Praxis Core results.

Content Knowledge Test (Praxis II)

All Conditional License holders must pass the Praxis II Subject Assessment for their specific teaching area. The full list of required tests is available at the MSDE Licensure Assessments page (marylandpublicschools.org/about/Pages/DEE/Certification/Assessments.aspx). Common examples:

Elementary Education: Praxis 7001 (Elementary Education Multiple Subjects)
Secondary Mathematics: Praxis 5161 (Mathematics: Content Knowledge)
Special Education: Praxis 5354 (Special Education: Core Knowledge) + TRE 5205 (for SpEd conditional license holders)
Secondary English: Praxis 5038 (English Language Arts: Content Knowledge)

Sources: MSDE Licensure Assessments page; HCPSS Educator Licensure page (hcpss.org/employees/certification/).

The HCPSS Praxis Reimbursement Program for Conditional License Holders

Howard County Public School System (HCPSS) provides a valuable financial benefit specifically for Conditional License holders that is worth highlighting as a model of best practice and as a practical resource for HCPSS educators.

Per the HCPSS Educator Licensure page: ‘The Howard County Public School System will reimburse MSDE Conditional Educator Certificate/License holders for Praxis exams required for professional licensure. Conditionally licensed individuals on a Provisional MD Teacher Contract are eligible for reimbursement of Praxis test fees for up to three (3) attempts per required licensure exam (pass or fail).’

Who qualifies: HCPSS Conditional Educator Certificate/License holders on a Provisional MD Teacher Contract
What is covered: Praxis exam fees for all required licensure exams — up to 3 attempts per exam (pass or fail)
Practical significance: Praxis exams can cost $100-$200 each; multiple attempts can represent high cost. HCPSS’s reimbursement program substantially reduces the financial burden of meeting testing requirements during the conditional license period.

Other Maryland school systems may have similar or different reimbursement programs. Candidates should ask their employing school system’s HR or licensure office about available Praxis fee assistance upon receiving a Conditional License.

Source: HCPSS Educator Licensure page (hcpss.org/employees/certification/) — Praxis reimbursement quote.

The July 2025 edTPA/PPAT Mandate for All Pathways

Effective July 1, 2025, all Maryland teacher certification candidates — including Conditional License holders working toward their Initial Professional License — must complete a performance-based pedagogy assessment. This is one of the most significant assessment changes in Maryland teacher certification in years.

July 1, 2025: edTPA or PPAT Required — PLT No Longer Accepted

BEFORE July 1, 2025: Candidates (including Conditional License holders) completing their pathway to the IPL could fulfill the pedagogy assessment by passing the Praxis PLT (Principles of Learning and Teaching).

FROM July 1, 2025 ONWARD: ALL teacher candidates — including those on Conditional Licenses — must pass either the edTPA or PPAT to fulfill the pedagogy assessment requirement. The PLT is no longer accepted.

Per HCPSS: ‘Effective July 1, 2025, teacher candidates must present the edTPA or PPAT to fulfill the pedagogy assessment requirement. The Praxis PLT will not be accepted after July 1, 2025.’

edTPA: Register at edtpa.com; portfolio-based; documents and video-records teaching across planning, instruction, and assessment tasks.

PPAT: Register at ets.org/ppat; ETS alternative portfolio assessment; similar structure.

FLEXIBLE PATHWAY EXCEPTION: For Conditional License holders employed in Maryland LEAs: an effective rating on a year-end formal evaluation may fulfill the pedagogy assessment requirement (MSDE Licensure Overview, April 2024).

IMPORTANT FOR CL HOLDERS: If you received a Conditional License before July 1, 2025 and plan to complete your IPL pathway after that date, you must complete edTPA or PPAT (or use the year-end evaluation option if LEA-employed).

Sources: HCPSS Educator Licensure page; MSDE Educator Licensure Overview (April 2024); research.com MD 2026.

No Endorsement Additions on Conditional Licenses

A critical restriction of the Conditional License is that additional teaching endorsements cannot be added to it. Per HCPSS: ‘Additional endorsements cannot be added to conditional certificates.’ This is distinct from a professional license, to which additional endorsements can be added after meeting relevant content test requirements.

What this means practically:

You cannot expand your conditional license scope: If you received a Conditional License to teach 7th grade mathematics, you cannot add a science endorsement to that same Conditional License. You must first complete your pathway to the IPL, then add endorsements to the professional license.
You can apply for a separate license if needed: If you need to teach in an additional content area that requires separate licensure, a separate application process would be required — which would typically require a separate school system request.
After receiving the IPL: Once you transition to the Initial Professional License, you can add endorsements through TEACH by passing the appropriate Praxis content test for each additional area.

Source: HCPSS Educator Licensure page (hcpss.org/employees/certification/) — ‘Additional endorsements cannot be added to conditional certificates.’

The Step-by-Step Application Process (TEACH Portal)

All Maryland teacher license applications — including requests for Conditional Licenses — are processed through the TEACH Dashboard at certificationhub.msde.maryland.gov (also accessible via mdcert.org and marylandpublicschools.org/TEACH). For most Conditional License applicants, the school system’s HR or licensure office handles the TEACH application process.

Process for the Employing School System

Verify the ‘cannot fill’ condition. The school system confirms that the position cannot be filled by a fully qualified, professionally licensed teacher. This determination is made by school leadership and HR.
Verify candidate meets BA requirement. Confirm the candidate holds a bachelor’s degree or higher from an accredited institution.
Submit Conditional License request through TEACH. The school system’s licensure designee logs into the TEACH Dashboard and submits the Conditional License request on behalf of the candidate. Per MSDE: ‘Teachers employed with a conditional license in a Maryland local education agency… should contact their employer’s licensure office/point of contact.’
Include required documentation: Official transcripts confirming bachelor’s degree; confirmation of candidate’s qualifications for the specific teaching area; documentation of the ‘cannot fill’ determination.
Criminal background check: All candidates must complete a criminal history background check before beginning classroom responsibilities. The school system typically handles this process.
MSDE processes and issues the license: MSDE reviews the request, verifies eligibility, and issues the Conditional License. Processing time is typically a few weeks for complete applications.
Candidate receives license through TEACH: The Conditional License is issued electronically and accessible through the TEACH portal. It is specific to the requesting school system and content area.

Sources: MSDE TEACH portal (certificationhub.msde.maryland.gov); MSDE Educator Licensure Overview (April 2024); HCPSS Educator Licensure page.

Process for the Candidate

While the school system primarily drives the Conditional License application, candidates should:

Ensure their official transcripts are available for submission (sent directly from institution)
Create a TEACH account at certificationhub.msde.maryland.gov if they do not already have one
Cooperate with the school system’s HR/licensure office throughout the process
Begin pursuing their pathway to professional licensure immediately upon receiving the Conditional License
Contact the employing school system’s HR/licensure office — not MSDE directly — as the first point of contact for guidance

What Conditionally Licensed Teachers Must Do During Their License Period

The Conditional License period is not a time to simply maintain the status quo — it is a defined window in which the conditional license holder must actively work toward full professional licensure. Here is a comprehensive action plan:

Year 1: Foundational Steps

Contact the school system’s HR/licensure office on Day 1 to map your specific pathway to the IPL
Determine which MAAPP programs are available through or affiliated with your school system
Enroll in an approved pathway (MAAPP, university ACP, or other MSDE-approved pathway)
Register for required Praxis assessments: identify the specific Praxis II tests for your content area; confirm whether your GPA exempts you from Praxis Core
Understand your school system’s Praxis reimbursement program (if available — HCPSS offers up to 3 attempts per test)
Begin the edTPA or PPAT preparation process — understand what the portfolio assessment requires

Years 2-4: Active Completion

Complete required coursework through your enrolled pathway program
Pass required Praxis II content assessment(s) for your certification area
If pursuing Elementary, Early Childhood, SpEd, or ESOL certification: complete reading instruction preparation and pass Praxis TRE #5205
Complete edTPA or PPAT assessment (or qualify for year-end evaluation pathway if LEA-employed)
Receive satisfactory teaching evaluations — these support both the pathway to IPL and any year-end evaluation used for pedagogy assessment

Final Year: Transition to IPL

Submit Renewal/Advancement application through TEACH Dashboard to transition from Conditional License to Initial Professional License
Upload all required documentation: transcripts, Praxis scores, edTPA/PPAT results, program completion verification
Pay the $10 MSDE license issuance fee
Develop your Individualized Professional Development Plan (IPDP) at IPL issuance — required within 6 months for LEA-employed teachers

From Conditional to Initial Professional License (IPL)

The ultimate goal of the Conditional License holder is the Initial Professional License (IPL) — Maryland’s entry-level professional teaching license. Understanding the exact requirements for the IPL transition helps Conditional License holders plan effectively.

IPL Requirements

Per COMAR 13A.12.02.02B and the MSDE Educator Licensure Overview, to receive the Initial Professional License, a candidate must complete one of the approved pathways under COMAR 13A.12.02.03, which include:

Completion of a Maryland-approved teacher preparation program (MAP) including a clinical internship
Completion of a MAAPP (leading to the Resident Teacher License and then IPL upon program completion)
The new flexible pathways: 5 years verified effective teaching at an approved Maryland nonpublic school; or in-district training program (if district offers it)
Pass all required assessments: Praxis Core or 3.0 GPA; Praxis II subject test; edTPA or PPAT (from July 2025)
Pass reading instruction assessment if in Elementary, Early Childhood, SpEd, or ESOL

IPL Characteristics

Validity: 5 years, renewable (meets the standard renewal requirements: 90 PDPs + IPDP, or National Board Certification)
Portability: The IPL is portable to other Maryland school systems and may be recognized through reciprocity in other states
Endorsements: Additional endorsements can be added to the IPL (unlike the Conditional License)
IPDP: Must develop an IPDP within 6 months of IPL issuance if employed in a Maryland LEA

Sources: COMAR 13A.12.02.02B; MSDE Educator Licensure Overview (April 2024); MSEA Certificate-to-License Conversion Chart.

Maryland’s Teacher Shortage Context: Why These Licenses Exist

Maryland’s non-standard licensing framework is not an administrative curiosity — it is a direct response to a documented and persistent teacher workforce crisis. Understanding the scale and nature of this shortage provides essential context for why the Conditional License, Conditional SpEd License, and related credentials are so widely used.

The Numbers

1,616 unfilled teaching positions (2021-22): Per MSDE/NCES data cited in teachercertificationdegrees.com MD (March 2026)
6,724 underqualified teachers (2021-22): Teachers considered underqualified for their positions, including those assigned to classrooms outside their certification fields on a temporary or emergency basis (teachercertificationdegrees.com MD, March 2026)
Regional salary competition: Maryland’s average starting teacher salary, while above some national benchmarks, faces competitive pressure from D.C. and Northern Virginia where total compensation can be significantly higher — making teacher recruitment challenging particularly in Maryland’s suburban counties

Why Conditional Licenses Are Issued

The most common reasons Maryland school systems issue Conditional Licenses:

Subject area shortages: Particularly in mathematics, science, computer science, and special education — areas where qualified certified teachers are chronically scarce
Geographic distribution: Rural Maryland counties struggle to attract certified teachers; urban districts face competition from higher-paying suburban employers
Career changer pipeline: Many career changers bring strong content knowledge but lack formal teacher preparation; the Conditional License provides a bridge while they complete an MAAPP or ACP program
Midyear vacancies: When a teacher resigns or retires mid-year, filling the vacancy quickly with a certified teacher is often impossible; the Conditional License provides immediate coverage

Sources: teachercertificationdegrees.com MD (March 2026) — 1,616 / 6,724 figures; U.S. DOE Teacher Shortage Area report 2023-24; NCTQ analysis.

Maryland Shortage Areas That Drive Non-Standard Licensing

Per the U.S. Department of Education Teacher Shortage Area report for 2023-2024, Maryland has designated shortages in the following areas. These are the content areas most likely to see Conditional Licenses issued:

Shortage Area	License Type Most Applicable	Notes
Special Education (all levels K-12)	Conditional Special Education License (F)	Most critical shortage; specific 3-year conditional SpEd license; IDEA constraints apply
Mathematics (secondary)	Conditional License (E)	Highly sought nationally; strong career alternative salary competition
Sciences (Physics, Chemistry, Biology)	Conditional License (E)	Physics and Chemistry most acute; candidates often hold degrees in field without teacher prep
Computer Science	Conditional License (E)	Fastest-growing shortage area; industry professionals as natural CL candidates
World Languages / Foreign Languages	Conditional License (E) or Adjunct License	Native speakers and language professionals; Adjunct License possible for specific programs
English Language Learners (ESL/ESOL)	Conditional License (E)	Growing ELL population in Baltimore, PG County, Montgomery County
Career and Technical Education (CTE)	Conditional License (E) — PTE pathway	Industry professionals; PTE certification available; bachelor’s degree exception may apply for some CTE areas

Sources: U.S. DOE Teacher Shortage Area report 2023-24 (tsa.ed.gov); teachercertificationdegrees.com MD (March 2026).

All Four Non-Standard License Types Side by Side

Feature	Conditional License	Conditional SpEd License	Temporary Professional	Adjunct License
COMAR	13A.12.02.02E	13A.12.02.02F	13A.12.02.02A	13A.12.02.02H
Validity	Up to 5 years	3 years	2 years	1 year
Renewable?	Non-renewable	Non-renewable	Non-renewable	Renewable (annually)
Education req.	BA+ (PTE exception)	BA+	Already has out-of-state prep or prior MD license	Content expertise; no BA required
Who it’s for	Career changers who can’t fill position	SpEd vacancies when certified SpEd unavailable	Out-of-state licensed teachers; failed renewal	Subject matter experts, not teacher-trained
Pathway required?	YES — must pursue IPL	YES — SpEd-specific pathway required	NO — already professionally prepared; just needs testing or renewal catch-up	Not explicitly required
Portal	TEACH (school system requests)	TEACH (school system requests)	TEACH (school system requests)	TEACH (superintendent requests)
Endorsement additions?	NO	NO	NO (presumably)	NO

Sources: COMAR 13A.12.02.02 (regs.maryland.gov; law.cornell.edu); COMAR 13A.12.01 General Provisions; MSEA Certificate-to-License Conversion (tabco.org, May 2024).

Common Questions and Pitfalls

Question/Pitfall	The Answer
‘I applied for a Conditional License through TEACH on my own.’	You can’t. The Conditional License must be requested by your employing school system — you cannot apply independently. Contact your school system’s HR/licensure office.
‘My Conditional Certificate from 2022 — can I renew it?’	Conditional Certificates issued before April 1, 2024 cannot be renewed. However, your school system can request a NEW Conditional License if you still haven’t met full requirements. The old certificate was converted to a license on April 1, 2024 and remains valid for 3 years through March 31, 2027.
‘I thought Conditional Licenses were only valid for 2 years.’	The regulatory change on April 1, 2024 extended the maximum validity to 5 years under COMAR 13A.12.02.02E. The old 2-year figure reflects the pre-2024 framework or individual school system practice. Confirm with your specific district.
‘I want to add a second endorsement to my Conditional License.’	You cannot. Additional endorsements cannot be added to conditional certificates/licenses. You must first complete your pathway to the IPL, then add endorsements to the professional license.
‘I passed the PLT in June 2025 — does that satisfy my pedagogy assessment for Maryland certification?’	Verify with MSDE. The July 1, 2025 deadline applies to the final pedagogy assessment submission for IPL. If you were completing requirements before July 1, 2025, the PLT may have been accepted. For any completion after July 1, 2025, edTPA or PPAT is required.
‘My school issued me a Conditional License but I haven’t enrolled in any preparation program.’	COMAR E(4) requires Conditional License holders to ‘pursue a pathway to professional licensure.’ Not enrolling in a preparation program violates the conditions of your license and may affect your ability to transition to the IPL. Enroll in a MAAPP or ACP program immediately.
‘I’m a SpEd teacher on a Conditional Special Education License — why is my validity shorter?’	Federal IDEA requirements impose stricter standards on SpEd teacher preparation. Maryland’s Conditional SpEd License is valid for 3 years (not 5) and requires pursuit of a specifically SpEd-focused preparation pathway (Regulation .03A(1) and (2)) — not just any general professional licensure route.

Maryland Emergency Teacher Certification Requirements: FAQs

Does Maryland have an emergency teaching certificate?

Maryland does not use the term ’emergency teaching certificate.’ Instead, Maryland has four types of non-standard teaching licenses that serve functions similar to what other states call emergency certificates: the Conditional License (up to 5 years), the Conditional Special Education License (3 years), the Temporary Professional Teacher License (2 years), and the Adjunct Teacher License (1 year, renewable). The Conditional License is the primary tool used when a school cannot fill a position with a fully qualified, professionally licensed teacher.

What are the requirements for a Maryland Conditional License?

Per COMAR 13A.12.02.02E: (1) The requesting school system must certify that it cannot fill the position with a fully qualified individual; (2) The candidate must possess a bachelor’s degree or higher (with a PTE exception for CTE areas that don’t require a bachelor’s degree); (3) The school system (not the candidate) submits the request to MSDE through TEACH; (4) The candidate must pursue a pathway to professional licensure. Assessment requirements also apply: qualifying scores on a basic skills test (or 3.0 GPA exemption) and a content knowledge area test (Praxis II) for the specific teaching area.

How long is a Maryland Conditional License valid?

Under the current COMAR 13A.12.02.02E (effective April 1, 2024): ‘A conditional license is valid for 5 years and may not be renewed.’ This changed from the old 2-year Conditional Certificate. Note that individual school systems may issue conditional licenses for shorter periods. The Conditional Special Education License is separately governed and valid for 3 years (not 5). Contact your school system’s HR/licensure office and MSDE ([email protected]) to confirm the specific validity period for your license.

Can I apply for a Maryland Conditional License myself?

No. The Conditional License ‘shall be requested’ by the employing local school system, State-operated school, or approved nonpublic school — not by the individual candidate. You cannot apply independently. The process must be initiated by the school system that is hiring you, and the school system must certify that it cannot fill the position with a fully qualified professional license holder. If you believe you need a Conditional License, contact your school system’s HR or licensure office to begin the process.

What happens if I don’t pursue professional licensure while on a Conditional License?

COMAR 13A.12.02.02E(4) states that a Conditional License holder ‘shall pursue a pathway to professional licensure.’ This is a legal requirement. Failing to pursue a preparation pathway may affect your ability to transition to the IPL and could have implications for your employment. The school system that sponsored your Conditional License is also responsible for supporting your pathway — contact their HR/licensure office if you have not been guided toward an appropriate preparation program.

What is the Temporary Professional Teacher License and who is it for?

The Temporary Professional Teacher License (COMAR 13A.12.02.02A) is a 2-year, non-renewable credential for two specific situations: (1) Out-of-state teachers who completed an out-of-state teacher preparation program or hold a valid out-of-state professional license but have not yet passed the required Maryland Praxis tests; (2) Maryland professional license holders who failed to meet their license renewal requirements (90 PDPs/IPDP). It is not a pathway for individuals who have never been professionally licensed or prepared.

What changed about emergency/conditional teacher certification in Maryland in 2024?

The April 1, 2024 COMAR 13A.12 regulatory overhaul made three major changes: (1) All ‘certificates’ became ‘licenses’ — the Conditional Certificate is now the Conditional License; (2) The maximum validity period for the general Conditional License extended from 2 years to 5 years under the new COMAR framework; (3) Conditional Certificates issued before April 1, 2024 cannot be renewed, but school systems can request new Conditional Licenses for employees. Certificate evaluations issued between January 1, 2020 and March 31, 2024 were automatically extended through March 31, 2027.

Maryland Emergency Teacher Certification Requirements: Conclusion

Maryland’s emergency teacher certification system operates through four distinct non-standard license types — the Conditional License, Conditional Special Education License, Temporary Professional Teacher License, and Adjunct Teacher License — each serving a specific gap in teacher availability.

Unlike some states’ emergency certification frameworks, Maryland’s system is tightly regulated: every non-standard license requires a school system determination that a qualified professional cannot be found; every Conditional License holder must pursue a defined pathway to professional licensure; and every applicant must meet assessment and degree requirements that maintain meaningful quality standards.

The April 1, 2024 COMAR overhaul brought important changes — notably extending the Conditional License validity to up to 5 years, converting all certificates to licenses, and clarifying that old Conditional Certificates cannot be renewed. The July 2025 edTPA/PPAT mandate adds a performance-based teaching requirement that applies to all candidates completing their pathways to the IPL after that date, including Conditional License holders.

For individuals currently on or being offered a Conditional License, the single most important action is to begin pursuing an approved pathway to the Initial Professional License immediately — not as an afterthought after a few years of teaching, but on Day 1.

Contact your school system’s HR/licensure office, identify which MAAPP programs or university ACP programs are available to you, understand the assessment requirements for your specific content area, and take advantage of any Praxis reimbursement programs your district offers.

For authoritative current requirements, always verify directly at COMAR 13A.12.02.02 (regs.maryland.gov/us/md/exec/comar/13A.12.02.02) and with MSDE at [email protected]. Requirements can change, and the regulatory text is the definitive source.