AI use in an accounting practice sits across several overlapping frameworks. None of them prohibit AI use, but each carries specific obligations that should be reflected in how a firm builds workflows and chooses vendors.
IRD positions and audit trail.
Inland Revenue has been increasingly explicit about expectations for audit trail and supervision in tax work, including when AI tools are involved. The practical implication is that every AI-assisted output (a working paper, a tax memo, a return calculation) needs to be reconstructable after the fact, with the underlying source documents, the AI-generated draft, and the human review and signoff all archived together. This is a process problem more than a technology problem, but it's easier to design in upfront than retrofit.
CA ANZ professional standards.
Members remain professionally responsible for AI-assisted work product. The standards on professional competence, confidentiality, due care, and integrity apply equally whether or not AI was involved. The workflow designs we recommend build in human signoff at every output step, with archived AI drafts as audit material, never as the final deliverable.
Privacy Act 2020.
Client tax data is personal information. Privacy Act obligations on collection, retention, security, and breach response apply to any AI tool processing client data. The two highest-impact considerations are vendor data residency (where the data physically sits) and the vendor's data-processing terms (specifically, whether client data may be used for training future models, which we strongly recommend prohibiting contractually).
Client engagement letter language.
We recommend adding a brief, plain-English clause to engagement letters covering AI use in the firm's processes. This isn't legally required, but it's becoming best practice, and it tends to reduce client questions rather than create them. The clause we typically draft covers: categories of AI tools used, protection of client data, the fact that human professional judgment remains the named accountant's responsibility, and a contact point if the client has questions.
Sample audit narrative.
For a tax-season working paper generated with AI assistance, a CA-ANZ-aligned audit trail looks like: source documents archived in the working paper file (as today), AI-generated draft archived alongside, lawyer or accountant's reviewed and edited version as the final deliverable, with a brief sign-off note recording the senior's review and any judgment calls made. None of this is novel. It mirrors the way a typical firm already documents human-only work.