Rapid development and seismic changes in the utilization and distribution of Information Technology have led the AICPA Professional Ethics Executive Committee to organize a task force to review and revise the Information Systems Design, Implementation, or Integration interpretation (ET §1.295.145) of the AICPA Code of Professional Conduct.  This interpretation takes effect on January 1, 2023, after several delays.

The interpretation and underlying Code identify unacceptable threats to the independence of accounting firms which provide both attest and financial information technology services to their clients.

Additionally, maintenance or other follow-on IT related services may also impair independence.

Questions such as the following are highly relevant based on the new interpretation:

  • Do you license or support software (even “over the counter” software) utilization for your clients?
  • Do you assist with installation or customization of software for clients (such as setting up general ledger accounts and establishing rules)?
  • Do any implementations or other services include the development of new code, even as part of an API (application programming interface)?

The answers to these and other questions determine whether an accounting firm is compliant or whether safeguards can be put in place to permit these services to continue.

Metz Lewis has developed a simple compliance program which includes an interview with questions precisely tailored to make these determinations and assist you in remaining in compliance with the new interpretation.

Please feel free to contact Barry Friedman or your Metz Lewis relationship attorney to answer any questions or to learn more.

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