Last month a pitch arrived in our editor inbox, the title of which was “Going Concern, meet the startup helping accounting firms turn old Slacks and emails into free money.” The email went on to describe their ask:
AI labs need real examples of how accounting work gets done to train agents. But the emails, internal messages and project histories showing that work typically stay inside firms.
Now, [company] is launching a program that pays eligible accounting firms with at least 10 employees to license those records. For firms looking for extra capital, it’s a way to earn from records they already have without taking on debt or giving up equity.
The press release they sent later had some more details:
Early AI systems learned largely from the public internet. Developers are now building AI agents that can carry out accounting tasks, coordinate projects and respond to business requests. To train them, labs need examples of how professionals work through problems and make decisions over time. Records of a firm’s day-to-day work across platforms such as Zoho and Microsoft 365 capture those steps, providing context that a finished report often cannot.
[Company] first recognized the opportunity through its own operating records, then extended the approach across its portfolio of acquired companies. Before opening the program to outside organizations, it developed tools to remove sensitive information and replace names and other identifying details.
Huh. I asked if they could provide more information on how the data is scrubbed because I was most curious about that part knowing how cagey accounting firms are — or are supposed to be — about their data and didn’t hear back. The thought kept gnawing at me: is this kosher? Surely some client protection regulation stands in the way of selling off data in this way?
Well gnaw no more, the AICPA is on it. Journal of Accountancy has published an article that addresses the sale of accounting firm data to these eager AI labs that are starving for more data to feed the training machine: Asked to sell firm data for AI training? Be very cautious. Written by AICPA Professional Ethics Division communications manager Kelly D. Mullins, the article clearly states that it does not claim AICPA rules categorically prohibit every data transfer, only that they caution firms to tread carefully if they’re thinking about handing their data over for AI training:
Offers to buy, receive, or otherwise use firm data for AI model training are rising. They can sound appealing, but client confidentiality obligations do not disappear because the data is redacted, labeled “anonymous,” or framed as a technology partnership. Before you say yes, you need to evaluate whether the disclosure is permitted, authorized, and consistent with your professional responsibilities.
Information you obtain to serve clients is not unrestricted inventory. The prudent default response to any request to sell, give, or share confidential client information for AI training is to decline unless you can clearly establish that the transaction is permissible.
The AICPA’s “Confidential Client Information Rule” (ET sec. 1.700.001) and related definition of “confidential client information” generally prohibit members in public practice from disclosing such information without the client’s specific consent, subject to the rule’s exceptions. A sale or other transfer intended to train an AI model does not eliminate that specific-consent requirement. Permission to process information in order to perform an engagement does not authorize you to hand the same information to a buyer (or any other party) to train an AI model.
A bit more:
Redaction does not, by itself, turn confidential client information into nonconfidential information. Removing names and other identifying details does not change the confidential nature of the underlying information or eliminate your obligations. The AICPA’s nonauthoritative Ethics Staff Insights: AI Through an Ethics Lens addresses this point in its discussion of the “Disclosure of Client Information to Third Parties” interpretation (ET sec. 1.700.060), which applies even when client information is disclosed without the client being specifically identified. If the information remains confidential client information, that interpretation requires the client’s specific consent — preferably in writing — before you disclose or use it. Do not treat redaction, or a buyer’s “anonymous data” label, as permission to sell, give, or share the information for model training.
Again, they’re not saying do not under any circumstances do this, nor are they saying they have the authority to issue such a concrete directive. They’re merely outlining the important considerations, including Sec. 7216 concerns that carry criminal consequences if knowingly or recklessly violated.
I’d be curious if any of you firm owners are seeing these offers hit your inbox. Let me know.
