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Board pack · Accountancy firms

The AI questions for your next board meeting.

Six questions for the boards of accountancy firms, with the regulators and duties they answer to. Table it, ask each question, and note which answers your organisation could evidence today.

The six questions.

  1. Which engagement types and client data are AI tools permitted to touch, and how do we guarantee confidential material never leaves systems we control or trains a third-party model?
  2. How do we evidence that a competent member has reviewed and takes responsibility for every AI-assisted output, and in audit that the engagement partner remains accountable for quality?
  3. Does our use of AI in tax work meet our PCRT and HMRC obligations, with the member, not the tool, responsible for the accuracy of every filing?
  4. Where AI screens clients or transactions for anti-money-laundering, are the checks adequate, explainable and backed by a human decision our AML supervisor would accept?
  5. What is our process for catching fabricated figures, misread documents and hallucinated positions before they reach a client, a filing or a court, and who owns that control?
  6. Do we have a DPIA and a lawful basis for any AI system processing personal or confidential client data under the UK GDPR, and does the board see the AI risk register?

What your board answers to.

  • ICAEW / ACCA Code of Ethics

    Binds chartered and certified accountants to competence, due care, confidentiality and objectivity. Revised technology provisions in force from 2025 require a member to judge whether an AI tool and its data are sufficient before relying on the output.

  • Financial Reporting Council (FRC)

    Its AI in audit guidance (2025, extended 2026) confirms that regulatory accountability and the human auditor's responsibility for audit quality are unchanged, with documentation expected on how AI tools are certified and used.

  • Information Commissioner's Office (ICO) and UK GDPR

    The firm is data controller for client and personal data processed by AI, requiring a lawful basis, a DPIA, and controls that keep confidential material out of third-party models and their training data.

  • HMRC agent obligations and PCRT

    Professional Conduct in Relation to Taxation, updated for AI, holds the member responsible for the accuracy of AI-assisted tax work. Standards for agents mean the firm answers to HMRC for filings, whatever tool prepared them.

  • Money Laundering Regulations 2017 and AML supervision

    Where AI screens clients or transactions for customer due diligence, the firm and its AML supervisor still require the checks to be adequate, explainable and evidenced, with a human decision on risk.

Want to know how your board would answer before the meeting? The Board AI Scorecard scores the five areas these questions test, in about two minutes.