If AI is used to review client source documents and build workpapers, does that trigger IRC 7216 disclosure/consent requirements?

The IRS has not updated Section 7216 to address AI directly, so there's no clear ruling on whether AI counts as an 'auxiliary service' (which wouldn't require separate client consent) or as a third party requiring disclosure and signed consent. Practitioners are split on this, and it comes down to each firm's own risk appetite, WISP (written information security plan), and engagement letter language. Some firms are exploring scrubbing PII from documents before AI ever sees them as a way to reduce risk, though even that approach is debated—some argue scrubbed data is still technically client tax information and may still fall under 7216, but again, there's no definitive guidance.