On June 24, 2026, the IRS Office of Professional Responsibility (OPR) published Introductory Guidelines for Responsible AI Use in Federal Tax Practice. It is not a regulation, but it is a formal signal from the agency that oversees practitioner discipline. For CPA firms using AI tools in client work, this bulletin maps directly to existing Circular 230 obligations.
If your firm uses AI for research, document drafting, tax return preparation, written advice, or IRS representation, you need to read this.
The OPR bulletin does not prohibit AI. It outlines how existing Circular 230 duties apply when AI is in the workflow. Five sections of Circular 230 are specifically addressed:
Section 10.22 - Due Diligence: Practitioners must review all AI-generated documents before delivering them to clients or submitting them to the IRS. AI output is not a finished work product. Every fact, citation, and calculation needs human verification.
Section 10.27 - Fees: Billing clients for time that AI handled without adjustment may violate fee standards. If AI cut the time on a task by 60%, billing the full manual rate could be an issue. The OPR expects cost savings to be passed on or disclosed.
Section 10.35 - Competence: Competence now includes understanding how the AI tools in use actually work, including their limitations. Practitioners are expected to recognize when AI output is biased or unreliable, not just whether the answer sounds correct.
Section 10.36 - Firm Procedures: Firm leadership is responsible. Principals must establish written procedures covering staff AI training, secure data handling, and vendor vetting. If a staff member causes a violation because the firm had no AI policy, the principals are exposed.
Section 10.37 - Written Advice: Any written advice to clients must be based on verified facts and law. AI projections, citations, or legal summaries cannot be passed through to clients without independent verification. If the AI's underlying logic is not transparent, relying on it may not meet the "reasonable" standard.
The bulletin also addresses IRC Sections 6713 and 7216, which carry civil and criminal preparer penalties for unauthorized disclosure of taxpayer information. Uploading client data to unsecured or public AI platforms is a direct exposure point.
The OPR bulletin is not theoretical. Courts have sanctioned attorneys for AI-generated hallucinations in filings, including financial penalties, required ethics courses, and referrals to bar authorities. The bulletin cites a case where Deloitte Australia delivered a government report containing invented quotes, references to non-existent reports, and books attributed to the wrong author. Deloitte reportedly refunded a portion of its fee to resolve the matter.
Tax professionals are next. The OPR bulletin states directly: "Cases imposing sanctions against other types of tax professionals are slowly emerging."
Most of the Circular 230 obligations above require something that is not a tax question. They require a firm to have operational controls in place:
A CPA firm cannot comply with Section 10.36 by telling staff to "be careful with AI." The OPR expects documented procedures and evidence of enforcement.
Specifically, the bulletin calls out:
PK Tech works with CPA firms to build and document exactly this kind of operational framework. We come out of the accounting industry and have maintained SOC 2 Type II attestation across our own operations, which means we understand what auditable controls look like in practice.
If your firm does not have a written AI policy, is using consumer-grade AI tools with client data, or cannot demonstrate to a regulator that staff training on AI risks has occurred, that is a gap worth addressing before the OPR does it for you.
The OPR's own summary from the bulletin provides a clear starting point:
If you'd like to discuss turning those requirements into documented IT policies, third-party AI assessments, and staff training your firm, contact us.
Source: IRS Office of Professional Responsibility, Introductory Guidelines for Responsible AI Use in Federal Tax Practice, Issue 2026-19, June 24, 2026.