IRC § 7216 and licensing CPA firm data to AI
What the rule covers
See the statute (26 U.S.C. § 7216) and the regulations on permitted disclosures, including statistical compilations (26 CFR § 301.7216-2).
Practical scoping
- Separate tax-practice systems from firm-administration systems.
- Keep returns, workpapers and client correspondence out unless counsel approves a consent route.
- Consider firm-authored SOPs, blank templates, internal training.
Buyer protections aren't a substitute
Buyers describe de-identification (Mode affiliate FAQ), but that doesn't by itself resolve a § 7216 question.
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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Start the free checkFrequently asked questions
Does anonymizing return data solve it?
Not necessarily. The regulations specifically address compilations. Ask a tax attorney.
Does § 7216 apply to bookkeeping-only firms?
It applies to people in the business of preparing returns. A firm's mix of services matters; ask counsel.
Sources
- 26 U.S.C. § 7216 (Cornell LII)
- 26 CFR § 301.7216-2 (Cornell LII)
- Mode affiliate FAQ (PDF, dated Oct 14, 2026)
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.