Short answer: Possibly, for firm-owned process records. Client ledgers, bank feeds and payroll data belong to clients and are usually covered by your engagement terms and privacy rules. Mode lists accounting at 15+ employees; Census counts 2,414 'other accounting services' firms, which include bookkeepers, with 15+.
On this page
What bookkeeping files hold
- Client general ledgers, bank and card feeds.
- Vendor and customer lists.
- Payroll registers and employee data.
- Client logins to banking and accounting platforms.
Rules that can apply
The FTC's Safeguards Rule requires covered financial institutions to protect customer information and oversee service providers (FTC Safeguards Rule). If you also prepare returns, IRC 7216 applies (§ 7216). Your engagement letters may add restrictions.
What could be in scope
- Month-end close checklists and SOPs.
- Client onboarding workflows with no client data.
- Internal chat about process, not client facts.
- Training materials.
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).
| Industry (U.S. firms, 2022) | All firms | 15+ staff | 30+ staff | 50+ staff |
|---|---|---|---|---|
| Other accounting services, incl. bookkeeping (NAICS 541219) | 45,390 | 2,414 | 1,239 | 827 |
| Accounting, tax prep, bookkeeping & payroll (NAICS 5412) | 120,085 | 8,067 | 3,808 | 2,368 |
Source: U.S. Census Bureau, Statistics of U.S. Businesses 2022, detailed employment sizes. Firms (enterprises) by paid employees; contractors are not counted. Each column sums the Census size classes at or above that size.
Before you call a buyer
This is general information, not legal advice. Talk to your own attorney or compliance advisor before you share or license any records.
What could your company's records be worth?
Answer 6 questions. See the published range for a company like yours and which program fits. Takes about a minute.
Frequently asked questions
Can we include client transaction data if names are removed?
Transaction patterns can identify businesses. Treat client ledgers as out of scope unless counsel approves.
Is bookkeeping 'accounting' for Mode?
Mode lists 'accounting' at 15+. Ask Mode how it classifies a bookkeeping-only firm.
Sources
- FTC Safeguards Rule: what your business needs to knowftc.gov
- 26 U.S.C. § 7216 (Cornell LII)law.cornell.edu
- Mode / BizBuyData referral pagebizbuydata.com
- U.S. Census Bureau, Statistics of U.S. Businesses 2022, detailed employment sizeswww2.census.gov
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.
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