Accounting firms · Last updated October 20, 2026

Can a 15-person CPA firm sell its data to AI?

Short answer: On size, yes for Mode: its published minimum for accounting is 15+ employees. On scope, tax return information is tightly restricted by federal law (IRC § 7216), so most of what a CPA firm can consider is its own firm-authored, non-client material. Get counsel to set scope before any call.

Size

Mode lists minimum team sizes of 10+ employees for legal, 15+ for accounting, medical and finance, and 50+ for all other businesses, for companies based in the US, Canada, the UK or Australia with several years of records they own (Mode). Accounting Today reported a 10-employee minimum for accounting firms when the program launched (Accounting Today); Mode's own page now says 15+, so go by the page.

Industry (U.S. firms, 2022)	All firms	10+ staff	15+	30+	50+
Accounting, tax prep, bookkeeping & payroll (NAICS 5412)	120,085	12,158	6,739	3,175	1,595
Offices of CPAs (NAICS 541211)	50,885	5,991	2,952	1,128	469

Source: U.S. Census Bureau, Statistics of U.S. Businesses 2022, detailed employment sizes. Counts are firms (enterprises) by paid employees; independent contractors are not counted. Sums of size classes at or above each threshold.

The § 7216 problem

IRC § 7216 penalizes tax preparers who knowingly or recklessly disclose or use return information beyond permitted purposes (26 U.S.C. § 7216). The regulations limit statistical compilations, including selling them (26 CFR § 301.7216-2).

The Safeguards Rule

The FTC treats tax preparers as financial institutions under the Safeguards Rule, which requires an information security program (FTC Safeguards Rule).

This is general information, not legal advice. Talk to your own attorney or compliance advisor before you share or license any records.

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Frequently asked questions

What could a CPA firm license?

Typically firm-authored material with no client facts, like internal SOPs and blank checklists, subject to counsel's review.

Is a 14-person firm eligible?

Not under Mode's current published minimum of 15+ for accounting.

Sources

Referral-fee disclosure: we may be paid by a program if your company signs with it after using this site. General information only, not legal advice.