AI acceptable-use policy for CPA and accounting firms
By Dan Blomquist, Aegis AI Advisory · Published October 20, 2026
An AI acceptable-use policy for a CPA or accounting firm is a short written rule set that says which AI tools staff may use, which client data may go into them, and who checks the output. For a tax and accounting practice it has to line up with four rules the firm already follows: IRC §7216 on tax return information, the AICPA confidentiality rule, the FTC Safeguards Rule, and Circular 230 due diligence.
A generic AI policy usually says “don't put confidential data into AI.” That is a start, but in a tax practice staff need to know which kind of confidential data, which tools, and what has to be in place first. The sections below cover those points and include sample wording you can adapt.
The four rules a CPA firm's AI policy has to fit
None of these rules mention generative AI by name. Each one already covers what happens when a staff member pastes client information into a tool run by someone else.
- IRC §7216, tax return information. Section 7216 makes it a misdemeanor for a tax return preparer to knowingly or recklessly disclose information furnished for a return, or use it for anything other than preparing the return. Its regulations list the disclosures allowed without consent (§301.7216-2) and set the form of a valid written consent (§301.7216-3). One detail matters for AI tools: even inside the same firm, disclosing tax return information to someone located outside the United States requires the taxpayer's consent first. Ask every AI vendor where it processes and stores data. The IRS keeps a Section 7216 information center.
- AICPA Code, confidential client information. The AICPA Code of Professional Conduct says a member in public practice shall not disclose confidential client information without the client's specific consent (ET 1.700.001). Its interpretation on third-party service providers (ET 1.700.040) says that before sharing that information with a provider, a member should either have a contract requiring the provider to keep it confidential, with reasonable assurance of its procedures, or get the client's specific consent. An AI vendor that receives client data is in a similar position.
- FTC Safeguards Rule. The FTC lists tax preparation firms among the financial institutions covered by its Safeguards Rule. Covered firms must keep a written information security program (16 CFR 314.4), oversee their service providers by contract, evaluate the security of third-party apps that handle customer information, and require multi-factor authentication. The IRS and Security Summit sample plan for small practices is Publication 5708.
- Circular 230 due diligence. Practitioners must exercise due diligence as to the accuracy of returns they prepare and of what they tell clients about IRS matters (31 CFR 10.22). An AI tool that drafts a memo or suggests a position doesn't change who is responsible for it.
A three-tier data rule for AI tools in a tax practice
The most useful part of a CPA firm's policy is a plain table that staff can check before they paste anything. This is the structure we recommend; your firm sets the exact tools.
| Type of information | Personal or free AI accounts | Firm-approved AI tool |
|---|---|---|
| Public: published tax law, IRS publications, general how-to questions | Allowed | Allowed |
| Firm internal, no client details: marketing drafts, internal checklists, blank templates | Not allowed for firm work | Allowed |
| Confidential client information: financial statements, engagement details, client names | Never | Only if the tool is approved for this data and the vendor is under a written confidentiality agreement (or the client has given specific consent) |
| Tax return information: anything furnished to prepare a return, including SSNs | Never | Only after the firm has confirmed a basis under the §7216 regulations (a listed exception or a signed taxpayer consent) and checked where the vendor processes data |
“Personal or free AI accounts” means any account that isn't owned and managed by the firm, including the free tiers of ChatGPT, Gemini and similar tools.
What the policy covers
A CPA firm's AI policy uses the same core sections as any professional firm's (see the free sample policy), with tax-specific rules added in four places:
- Approved tools: a named list, and who approves new tools (for example, the partner who serves as the firm's Safeguards Rule Qualified Individual).
- Client and tax return data: the tiers above, with the §7216 consent check written in.
- Human review: a named reviewer for anything AI touches in a return, workpaper or client letter.
- Security and vendors: AI vendors that handle client information go on the WISP's service-provider list, with firm accounts, MFA and model training turned off where the tool allows it.
The other sections, covering purpose, scope, disclosure, incident reporting, and training and acknowledgment, stay close to the general version. Our article on what an SMB AI acceptable-use policy should contain explains each one.
Sample policy excerpt for an accounting firm
Excerpt for illustration only. Not legal advice. [Firm] and [Approver] are placeholders.
4. Client and tax return information
Staff must not enter tax return information, Social Security numbers or client financial records into any AI tool unless (a) the tool is on the Approved AI Tools list for that type of information, (b) the firm has a written confidentiality agreement with the vendor, and (c) [Approver] has confirmed the use is permitted under IRC §7216 and its regulations, including any required taxpayer consent.
5. Human review
AI output used in a tax return, workpaper or client communication must be reviewed by a qualified staff member before it is relied on or sent. AI-suggested tax positions and citations are research leads to be verified against primary sources, not conclusions.
7. Security
AI tools that handle client information are treated as service providers under [Firm]'s Written Information Security Plan. Staff use firm accounts with multi-factor authentication, and model training on firm data is turned off where the tool allows it.
Rolling it out in a small firm
- Find out what is already in use. Ask staff which AI tools they use for work, with no penalty for honest answers. Our guide to shadow AI explains why this step comes first, and five signs of shadow AI covers what to look for.
- Pick the approved tools and fill in the data tiers. Use business plans you control, not personal accounts.
- Check vendor terms and locations. Confirm confidentiality terms, training settings and where data is processed, then add each vendor to your WISP.
- Settle consent and engagement-letter wording with counsel for any workflow that puts client or tax return information into an AI tool.
- Train staff and collect signed acknowledgments, then review the policy each year or whenever you add a tool. Our 90-day AI governance plan shows one way to sequence this.
What isn't settled yet
Be careful with anyone who claims certainty here. As of this writing, the §7216 regulations and the AICPA Code don't name generative AI. Whether a given AI vendor counts as a provider of “auxiliary services” under the §7216 rules, or as “administrative support” that the AICPA's third-party service provider interpretation exempts from client notice, depends on what the tool does with the data, and the rules don't answer that directly. State boards of accountancy and state privacy laws can add requirements of their own. A policy reduces risk by making these decisions explicit. It does not replace advice from your attorney.
Get a policy written for your accounting firm
Answer 10 questions, choose Accounting / CPA, and the generator emails you a policy for your state and the tools your staff use. It covers 7216 consent, AICPA confidentiality, the Safeguards Rule and review of AI-generated tax positions.
- $49 Policy: AI acceptable-use policy (Word + web version) and a one-page staff checklist.
- $149 Pro Pack: adds an AI vendor risk register and a staff training sign-off sheet.
Not ready? Read the free sample policy first.
Disclosure: Aegis AI Advisory sells this generator. It produces a template, not legal advice. It is not the right fit if your counsel has already drafted an AI policy for you, or if you need a legal opinion on a specific §7216 consent question. For a larger firm that needs an AI usage inventory, vendor review and training program, see the AI governance track or book a free AI Operations Briefing.
Frequently asked questions
Can CPA firm staff use ChatGPT with client data?
Not by default. A public or personal chatbot account is a third party with no confidentiality agreement with your firm, so client information should stay out of it. A firm-approved AI tool can be used for client data only if the policy approves it for that data class, the vendor is bound by a written confidentiality agreement or the client has consented, and tax return information has a documented basis under the IRC 7216 regulations.
Does IRC 7216 apply to AI tools?
Section 7216 and its regulations do not mention AI tools by name. They make it a crime for a tax return preparer to knowingly or recklessly disclose or use tax return information for unauthorized purposes, and they list the disclosures allowed without the taxpayer's written consent. Whether a particular AI tool or vendor fits one of those exceptions is a question to settle with counsel. Until it is settled, the safe policy rule is that tax return information does not go into an AI tool without either a confirmed exception or a signed 7216 consent.
Does the AICPA Code of Professional Conduct address AI?
Not by name. But the Confidential Client Information Rule (ET 1.700.001) bars disclosing confidential client information without the client's specific consent, and the interpretation on third-party service providers (ET 1.700.040) says that before sharing confidential client information with a provider, a member should either have a contract requiring the provider to keep it confidential, with reasonable assurance of its procedures, or get the client's specific consent. An AI vendor that receives client data is in a similar position, so the policy should require one of those two before client data goes in.
Is an AI policy the same as a Written Information Security Plan (WISP)?
No. The FTC Safeguards Rule requires tax preparation firms to keep a written information security program, which the IRS calls a WISP. An AI acceptable-use policy is narrower: it tells staff which AI tools they may use and with what data. The two should point to each other, and AI vendors that handle client information belong on the WISP's list of service providers.
Who should review AI output in a tax or accounting practice?
A qualified person who is responsible for the work, before anyone relies on it or sends it to a client. Circular 230 requires practitioners to exercise due diligence as to the accuracy of returns and of what they tell clients about IRS matters, and AI-drafted content does not change who is responsible. Treat AI-suggested tax positions as research leads to verify, not conclusions.
Do we have to tell clients we use AI?
It depends on what the AI tool does with client information. The AICPA interpretation on using a third-party service provider (ET 1.150.040) says a member should inform the client, preferably in writing, before disclosing confidential client information to one, and that this is not required for administrative support services such as software hosting. Many firms address AI use in the engagement letter. Have counsel confirm the wording for your firm and state.
What does the Aegis AI policy generator produce for an accounting firm?
Pick Accounting / CPA as your industry and answer 10 questions. The $49 Policy is an AI acceptable-use policy in Word and web versions plus a one-page staff checklist, written for your state and the tools you use, with sections that address 7216 consent, AICPA confidentiality, the Safeguards Rule and review of AI-generated tax positions. The $149 Pro Pack adds an AI vendor risk register and a staff training sign-off sheet. It is a template, not legal advice.
Sources
- 26 U.S.C. §7216, disclosure or use of information by preparers of returns
- 26 CFR §301.7216-2 (permitted disclosures without consent) and §301.7216-3 (taxpayer consent)
- IRS Section 7216 information center
- AICPA Code of Professional Conduct: ET 1.700.001, 1.700.040 and 1.150.040
- FTC, Safeguards Rule: What Your Business Needs to Know and 16 CFR 314.4
- IRS Publication 5708, Creating a Written Information Security Plan for your Tax & Accounting Practice
- 31 CFR 10.22, Circular 230 diligence as to accuracy
Also free: check whether ChatGPT and Google's AI can find your firm → · More guides on the resources page.