42 Georgia State Licensing Boards Pay $3M in First-Ever DOJ SCRA Action Against State Agencies

On March 31, 2026, the Department of Justice announced a $3 million settlement with 42 Georgia state professional licensing boards for alleged violations of the Servicemembers Civil Relief Act. The boards collectively failed to recognize the out-of-state professional licenses of military servicemembers and their spouses, leaving an estimated 5,000 servicemembers and military spouses with denied or delayed applications.

This is the first DOJ SCRA enforcement action of its kind against state government agencies. Every prior SCRA settlement we have covered, from Greystar to CarMax to ADT to last week’s Vehicle Management Solutions, targeted private companies. This one targets state governments. The compliance implications are different, and they reach beyond Georgia.

The Statute You May Not Know Exists

The case rests on a relatively new SCRA provision: 50 U.S.C. Section 4025a, the professional licensing portability requirement added by the Veterans Auto and Education Improvement Act of 2022 (VAEIA). The provision took effect in January 2023.

Section 4025a requires state and territorial licensing authorities to accept the out-of-state professional license of a servicemember or military spouse as the equivalent of an in-state license, provided three conditions are met:

1. The license is in good standing
2. The licensee has actively used the license for two of the preceding three years
3. The licensee submits to the authority of the receiving state for purposes of standards of practice and discipline

When all three conditions are satisfied, the receiving state must allow the servicemember or spouse to practice their profession under the existing out-of-state license. The provision exists to address a recurring problem in military families: a PCS move that forces a spouse to surrender months of earnings while waiting for a new state to process a license they already hold.

Most compliance officers at financial institutions and property managers have never heard of Section 4025a, because it does not apply to them. It applies to state agencies. But the Georgia case demonstrates that the DOJ enforces every SCRA provision with the same penalties, regardless of which entity holds the obligation.

What the Georgia Boards Did

The DOJ’s investigation found that 42 Georgia state licensing boards failed to comply with Section 4025a after it took effect in January 2023. The boards either denied applications outright or imposed processing delays that effectively defeated the purpose of the licensing portability provision. Approximately 5,000 servicemembers and military spouses are estimated to be entitled to compensation under the settlement.

Assistant Attorney General Harmeet K. Dhillon stated: “Members of the military and their families already make great sacrifices to defend our nation. They should not have to sacrifice their professional careers or financial well-being because the military requires them to move.”

U.S. Attorney Theodore S. Hertzberg added: “The agreement we are announcing today allows service members and their spouses to focus on what is most important when military service sends them to Georgia.”

The Settlement Terms

Under the agreement, the 42 Georgia boards must:

• Pay up to $3 million in compensation to affected servicemembers and military spouses
• Adopt SCRA-compliant policies for processing military spouse and servicemember license applications
• Provide streamlined application processes for applicants with out-of-state licenses
• Train staff on Section 4025a requirements

Eligible applicants who were denied or delayed since January 2023 can submit claims through the U.S. Attorney’s Office for the Northern District of Georgia (USAGAN.CivilRights@usdoj.gov or 404-581-4626).

Why This Matters for Every State

There is nothing special about Georgia under Section 4025a. The provision applies identically to every state, every territory, and every professional licensing authority in the country. If Georgia’s licensing boards systemically failed to comply, other states have likely failed too.

Section 4025a creates a unique enforcement profile. Licensing boards are typically structured as quasi-independent state agencies, each with its own application processes, fee schedules, and reciprocity arrangements. The provision overrides all of that for qualifying servicemembers and spouses, but most boards have not updated their workflows accordingly. The Georgia case did not turn on one bad licensing decision. It turned on a pattern of bureaucratic processes that had not been adjusted to accommodate the federal requirement.

The compliance gap is structural:

• Most state licensing applications do not ask about military service. If the application does not capture the relevant facts, the board cannot apply the SCRA exception.
• Reciprocity arrangements are negotiated state by state. Section 4025a creates a federal floor that supersedes state reciprocity terms, but boards often rely on the state-level arrangements they already have.
• Processing delays are baked into the system. State licensing applications routinely take weeks or months. Section 4025a does not impose a specific processing deadline, but the DOJ treated extended delays as functionally equivalent to denials.

For a military spouse who is a licensed nurse, teacher, attorney, accountant, real estate agent, or any other licensed professional, those structural failures translate to months of lost income after a PCS move. Section 4025a was designed to eliminate exactly that gap.

What This Means for the Broader SCRA Enforcement Landscape

The Georgia case signals something larger about how the DOJ is reading the SCRA’s scope.

The agency now actively enforces every SCRA provision, not just the high-profile financial protections (interest rate caps, foreclosure restrictions, vehicle repossession). The 2026 enforcement record is illustrative:

• CarMax (Feb 2026): Section 3952 vehicle repossession
• Georgia Licensing Boards (Mar 31): Section 4025a professional licensing
• S&K Towing (Mar 25): Section 3958 storage liens
• ADT (Apr 14): Section 3956 consumer contract termination
• Rental Marketing Solutions (May 13): Section 3931 default judgment affidavits
• Vehicle Management Solutions (May 28): Section 3958 storage liens

Six enforcement actions in four months, covering five distinct SCRA provisions. The DOJ is not concentrating on a single statutory section. It is enforcing the entire statute, against every category of obligated party: lenders, landlords, towing companies, consumer service providers, and now state government agencies.

Since 2011, the DOJ has now obtained over $489 million in monetary relief for more than 152,000 servicemembers through SCRA enforcement. That number reflects sustained enforcement across multiple administrations, multiple SCRA provisions, and multiple categories of defendants.

The Compliance Takeaway

For private organizations: the Georgia case is a reminder that the SCRA covers more than the protections you have probably trained on. Section 4025a is one example. Section 3956 (consumer contract termination, the ADT statute) is another. If your business touches military families in ways that go beyond credit and tenancy, you may have SCRA obligations you are not currently checking.

For state agencies and licensing authorities: the Georgia settlement establishes that DOJ enforcement reaches state government. Any state board that has not updated its application processes for Section 4025a after January 2023 is operating at risk. The fix is not technically complex (verify military status, accept qualifying out-of-state licenses, adjust application workflows) but it requires deliberate effort. The Georgia boards did not do that, and the cost was $3 million plus reputational exposure.

The common thread, across every 2026 enforcement action: check before you act. Verify military status. Apply the protection the statute requires. Document the verification. The institutions that fail to do this end up funding settlements that compensate the servicemembers and spouses they overlooked.

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civrel.io verifies military status against the Department of Defense database, monitors for status changes, and produces the documentation every compliance program needs. Whether your obligation runs under Section 3931, 3937, 3952, 3953, 3956, 3958, or 4025a, the underlying requirement is the same: check first. Request a free portfolio scan.