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Accounting & Audit — AI Governance Landscape

Publisher

Ontic Labs

Version

v1

Last verified

February 15, 2026

Frameworks

AICPA Professional StandardsCircular 230GAO Yellow Book (GAGAS)IRC / Treasury RegulationsISAE 3000/3402 (international)PCAOB Auditing StandardsPCAOB standards (if audit-adjacent)SEC independence rulesSOX Section 404SSAE 18 (attestation)Sarbanes-Oxley (if public company clients)State board of accountancy rules

Industries

accounting audit

Accounting & Audit - Overview

The Big Four have committed $20B+ combined -- the largest AI investment outside big tech. Adoption jumped from 9% to 41%. Governance is 25%. The irony is structural: the industry that audits everyone else cannot yet audit its own AI. Ontic closes that gap.

The Big Four have committed over $20 billion combined to AI -- the largest investment outside big tech. Adoption jumped from 9% to 41% in a single year. Governance is 25%. The irony is structural: the industry that audits everyone else cannot yet audit its own AI. When an AI-assisted audit workpaper supports a financial statement opinion, PCAOB standards and AICPA professional requirements demand the same documentation rigor as human-prepared work. The engagement partner's signature still carries personal liability. AI does not change that equation -- it accelerates it. Tax advisory, forensic accounting, and assurance practices are all deploying AI-generated analysis that flows directly into client deliverables. The audit trail from model output to signed opinion needs to be as defensible as the opinion itself.

This industry includes 2 segments in the Ontic governance matrix, spanning risk categories from 3_evidentiary through 3_evidentiary. AI adoption index: 5/5.

Accounting & Audit - Regulatory Landscape

The accounting & audit sector is subject to 12 regulatory frameworks and standards across its segments:

  • AICPA Professional Standards
  • Circular 230
  • GAO Yellow Book (GAGAS)
  • IRC / Treasury Regulations
  • ISAE 3000/3402 (international)
  • PCAOB Auditing Standards
  • PCAOB standards (if audit-adjacent)
  • SEC independence rules
  • SOX Section 404
  • SSAE 18 (attestation)
  • Sarbanes-Oxley (if public company clients)
  • State board of accountancy rules

The specific frameworks that apply depend on the segment and scale of deployment. Cross-industry frameworks (GDPR, ISO 27001, EU AI Act) may apply in addition to sector-specific regulation.

Accounting & Audit - Audit & Assurance -- Big Four / National

Risk Category: 3_evidentiary Scale: Enterprise Applicable Frameworks: PCAOB Auditing Standards, AICPA Professional Standards, SSAE 18 (attestation), GAO Yellow Book (GAGAS), SOX Section 404, ISAE 3000/3402 (international), SEC independence rules

The industry that audits AI governance must first audit its own.

The Governance Challenge

Big Four and national audit firms deploy AI for internal technical memos, standard workpaper templates, client-facing findings, management letter drafting, and control mapping. PCAOB Auditing Standards, AICPA Professional Standards, and SSAE 18 attestation requirements demand documentation rigor for every workpaper — human or AI-generated. GAO Yellow Book applies to government audits. SOX Section 404 internal control opinions carry personal liability for the engagement partner. When an AI-assisted audit workpaper supports a financial statement opinion and the PCAOB inspects it, the provenance chain from model output to signed opinion must be complete.

Regulatory Application

PCAOB Auditing Standards govern AI-assisted audit workpapers. AICPA Professional Standards apply to all AI-generated engagement documentation. SSAE 18 attestation requirements apply to AI-assisted attestation engagements. GAO Yellow Book (GAGAS) applies to AI-assisted government audits. SOX Section 404 internal control opinions carry personal partner liability. ISAE 3000/3402 applies to international attestation. SEC independence rules constrain AI tool procurement and usage.

AI Deployment Environments

  • Studio: Internal technical memo drafting | Standard workpaper templates
  • Refinery: Client-facing findings and management letter drafting with control mapping
  • Clean Room: Evidentiary workpapers with chain-of-custody | PCAOB/GAO-ready narrative governance

Typical deployment path: Clean Room → clean_room (primary) | refinery for engagement-level governance

Evidence

  • Big Four have announced more than $20B in combined AI investments over multi-year programs
  • In our research, AI use in audit functions jumped from 9% to 41% in one year; governance is 25%
  • PCAOB inspection authority extends to AI-assisted workpapers under existing standards
  • Engagement partner personal liability is unchanged by AI assistance

Accounting & Audit - Accounting & Tax Advisory

Risk Category: 3_evidentiary Scale: Mid-Market-Enterprise Applicable Frameworks: IRC / Treasury Regulations, Circular 230, AICPA Professional Standards, PCAOB standards (if audit-adjacent), State board of accountancy rules, Sarbanes-Oxley (if public company clients)

Circular 230 due diligence applies to AI-assisted tax positions the same way it applies to human-prepared ones.

The Governance Challenge

Tax advisory practices deploy AI for tax research summarization, engagement letter drafting, internal memos, client-facing tax position narratives, return preparation governance, and advisory opinion documentation. Circular 230 imposes due diligence requirements on tax practitioners — including for positions supported by AI-generated research or analysis. AICPA Professional Standards apply to AI-assisted tax engagements. When the IRS examines a tax position and the supporting analysis was AI-generated, the practitioner must demonstrate the same due diligence standard as if a human prepared it. "The model researched it" does not satisfy Circular 230.

Regulatory Application

IRC and Treasury Regulations govern AI-assisted tax analysis. Circular 230 imposes practitioner due diligence requirements on AI-assisted tax positions. AICPA Professional Standards apply to AI-assisted tax engagements. PCAOB standards apply to audit-adjacent tax work. State boards of accountancy govern AI-assisted practice. Sarbanes-Oxley applies to tax positions for public company clients.

AI Deployment Environments

  • Studio: Tax research summarization | Engagement letter drafting | Internal memo assist
  • Refinery: Client-facing tax position narratives | Return preparation governance | Advisory opinion documentation
  • Clean Room: IRS examination defensibility | Tax court evidence files | Multi-jurisdiction position governance

Typical deployment path: Refinery → Refinery → Clean Room

Evidence

  • Circular 230 due diligence requirements apply to AI-assisted positions without exception
  • IRS examination of AI-assisted tax positions is increasing
  • State board of accountancy AI guidance emerging across jurisdictions
  • Tax advisory AI adoption is accelerating from the Big Four down to regional firms