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CPA Firm AI Acceptable Use Policy — Circular 230, AICPA Ethics | Polygraf AI

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CPA Firm AI Acceptable Use Policy

IRS Circular 230 due diligence, AICPA ET 1.700 client confidentiality — one policy covering both.

Managing partners, ethics leads, and technology committees at CPA firms of all sizes — from sole practitioners to regional firms — that use AI tools in tax, audit, advisory, or administrative workflows.

AI adoption in accounting surged from 9% to 41% in 2025, but the professional ethics framework — Circular 230, AICPA Code, state CPA society rules — has not changed. The question of whether entering client financial data into ChatGPT violates confidentiality rules has not been clearly answered for most practitioners.

A complete CPA firm AI policy covering: the professional ethics foundation (Circular 230 Section 10.22, AICPA ET Section 1.700), AI tool classification (approved for client work / administrative only / prohibited), specific requirements for tax preparation, audit, and advisory workflows, engagement letter AI disclosure framework, and annual training requirements.

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