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Security & compliance Open question — the Lab is working on this

Do we still need a separate Section 7216 consent/engagement letter when using AI tools like Claude for tax work?

23:29From the June 24 call · New IRS and AICPA AI Guidance: 7216, Billing, and Disclosures

Views differed. One member had Claude review the new guidance and, based on that analysis, still believes a separate 7216 engagement letter is needed — even for tools like Claude Teams, which Claude itself suggested falls within the 'enterprise level AI' perimeter described in the guidance, though it's not the same as Claude Enterprise. That member also had Claude draft language to add to their WISP (written information security plan). Another member's view was that nothing has fundamentally changed: as long as you're using compliant, SOC 2 Type 2 models, a separate 7216 consent isn't necessarily explicitly required — reasoning that storing client files in an AI tool isn't functionally different from storing them in a tool like Canopy. He agreed getting a 7216 isn't a bad idea, but doesn't think it's mandatory under current guidance.

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