What does AICPA Code 1.700 say?
ET section 1.700.001, the Confidential Client Information Rule, says a member in public practice shall not disclose any confidential client information without the specific consent of the client, subject to stated exceptions. The Code's definition covers information obtained from the client that is not available to the public.
See the AICPA Code of Professional Conduct (ET 1.700.001 and the definition in ET 0.400). The Code also notes that federal, state, or local rules may be more restrictive than the Code itself.
Does redaction or anonymizing the files remove the duty?
Not by itself. The AICPA has said that removing names and other identifying details does not change the confidential nature of the underlying information. The Disclosure of Client Information to Third Parties interpretation, ET 1.700.060, can apply even when the client is not specifically identified.
Kelly D. Mullins of the AICPA Professional Ethics Division wrote this up in the Journal of Accountancy on Nov. 2, 2026: Asked to sell firm data for AI training? Be very cautious. I cover the search phrase itself in Can accounting firms sell anonymized data?
How does that caution apply to a data-licensing discussion?
The prudent default, as the Journal of Accountancy put it, is to decline a request to sell, give, or share confidential client information for AI training unless you can clearly establish that the transaction is permissible. Permission to use information to perform an engagement is not the same as permission to license it to a buyer.
Firm-owned operational records that are not confidential client information are a different conversation. Even then, please confirm the line with your own counsel or ethics advisor. See Can a CPA firm license its data?
What about state accountancy rules?
State boards of accountancy and state statutes may impose confidentiality or records rules that are tighter than the AICPA Code. The Code itself warns that federal, state, or local requirements may be more restrictive. I can't recite every state's rule here, and I don't try to.
Ask your own counsel or ethics advisor what your state board requires before you describe any client-related records to a buyer. Nothing on this site is a substitute for that review.
Is this ethics or legal advice?
No. I'm pointing you to published AICPA rules and a Journal of Accountancy article so you can take them to your own advisor. I don't decide what your firm can disclose. Balance Sheet Data does not speak for the AICPA, and it is not a buyer.
If you still have process questions, book a free 15-minute call or apply directly.
FAQ
What does AICPA Code 1.700 say?
ET section 1.700.001, the Confidential Client Information Rule, says a member in public practice shall not disclose any confidential client information without the specific consent of the client, subject to stated exceptions. The Code's definition covers information obtained from the client that is not available to the public.
Does redaction or anonymizing the files remove the duty?
Not by itself. The AICPA has said that removing names and other identifying details does not change the confidential nature of the underlying information. The Disclosure of Client Information to Third Parties interpretation, ET 1.700.060, can apply even when the client is not specifically identified.
How does that caution apply to a data-licensing discussion?
The prudent default, as the Journal of Accountancy put it, is to decline a request to sell, give, or share confidential client information for AI training unless you can clearly establish that the transaction is permissible. Permission to use information to perform an engagement is not the same as permission to license it to a buyer.
What about state accountancy rules?
State boards of accountancy and state statutes may impose confidentiality or records rules that are tighter than the AICPA Code. The Code itself warns that federal, state, or local requirements may be more restrictive. I can't recite every state's rule here, and I don't try to.
Is this ethics or legal advice?
No. I'm pointing you to published AICPA rules and a Journal of Accountancy article so you can take them to your own advisor. I don't decide what your firm can disclose. Balance Sheet Data does not speak for the AICPA, and it is not a buyer.