Can an ICAEW or ACCA practice use an AI worker?
Yes. Neither code of ethics bars AI. What they require on confidentiality, competence and the output of technology, and what stays with a named accountant.
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5 minute read
Yes. Neither ICAEW's Code of Ethics nor ACCA's Code of Ethics and Conduct bars a practice from using AI. Both rest on the same international code and both judge the use by principles the profession already works to: confidentiality, and professional competence and due care. Both add a direct requirement from the international code: an accountant who intends to use the output of technology must determine whether that use is appropriate for the purpose. Responsibility for the work stays with the accountant.
Two codes with one foundation
ICAEW's Code of Ethics, in the edition that applies from 1 July 2026, binds its members, the employees of a member firm and member firms, and says it is derived from the code of the International Ethics Standards Board for Accountants (IESBA). ACCA says it adopts the IESBA Code in full, with later revisions "in their entirety and unaltered", and its Code binds members, affiliates, registered students and ACCA firms. Both set out the same five fundamental principles: integrity, objectivity, professional competence and due care, confidentiality and professional behaviour.
These codes follow the member, not the country. The paragraph numbers below are ICAEW's. An ACCA practice should read the corresponding text in the ACCA Rulebook.
What do the codes require on confidentiality?
ICAEW's Code says the safe approach is to assume that all unpublished information about a client's affairs is confidential (114.0 A1). An accountant must not disclose it, or use it for the advantage of the accountant, the firm or a third party (R114.2), unless there is a legal or professional duty or right to do so or the client has authorised it (R114.3), and must take reasonable steps to ensure that personnel under the accountant's control, and individuals from whom advice and assistance are obtained, comply with the same duty (R114.1). Keeping information confidential means protecting it "in the course of its collection, use, transfer, storage or retention, dissemination and lawful destruction" (114.1 A1).
A practice will ask any provider where client information is kept and what else it is used for. We say one thing on that: Your data is stored in the UK, and is never used to train AI models. Client records are also personal data, and the contract UK GDPR requires between a practice and its processor is set out in our article on AI workers and client data under UK GDPR.
What do they require when you rely on technology?
Competence includes technology. Maintaining professional competence requires a continuing awareness and understanding of "technical, professional, business and technology-related developments" relevant to the accountant's work (113.1 A3).
The output of technology. An accountant who intends to use the output of technology in a professional activity "shall determine whether the use is appropriate for the intended purpose" (R320.11).
The Code's factors to consider include (320.11 A1): the nature of the activity the technology performs; how far its output will be relied on; whether the accountant can understand, use and explain the technology, or has access to someone who can; the accountant's prior experience with it and whether its use for the purpose is generally accepted; whether it has been tested and evaluated for the purpose; the firm's oversight of how it is built, run and updated; the controls over who has access to it; and whether its inputs are appropriate.
Each is a question a provider can be asked. A role is set up with a written specification, a log of each change and who approved it, and a named reviewer. The determination itself is the accountant's.
Does this change who is responsible for anti-money laundering checks?
No. The UK's Money Laundering Regulations 2017 allow customer due diligence to be applied through an agent or an outsourcing service provider only on the footing that the practice remains liable for any failure to apply it. How the line is drawn inside the work is covered in AI and AML and KYC compliance admin.
Where does an AI worker fit in a practice?
Each AI worker has one role and a specification the practice has approved. The roles that fit are built on gathering and chasing, and none touches audit work: requesting a client's records ahead of a deadline and reminding them until the records arrive, which is chasing clients for documents; reading receipts and bank lines and proposing a coding for a bookkeeper to approve, which is bookkeeping data entry; collecting ID and company information for a new client's file; and reminding clients of unpaid fees. Our accountancy page describes each role, and how to scale an accountancy practice without hiring argues for them.
What stays with a named accountant?
Taking on a client. The risk assessment and the decision to accept belong to a named person at the practice.
Suspicion. Anything that looks wrong goes to your money laundering reporting officer. The worker reports what it found, decides nothing and says nothing of it to the client.
Advice. A client's question about tax or their accounts goes to the client manager.
Anything filed or signed. Returns, accounts and anything sent to HMRC or Companies House are approved and submitted by your people.
The books. Coding is proposed; a bookkeeper approves it.
Money. The worker makes no payment and moves no client money.
Which of the practice's own procedures change before a worker starts depends on its policies. This article states what the codes require and does not advise on how to comply.
A practice would give the worker the chasing for records and the proposed coding, and keep with its accountants the approval of the books and everything filed or signed in their name. The Code asks you to determine whether a use of technology is appropriate for its purpose, and a written role is what you would test. Talk to our agent.
Carlos Oliveira
Founder of The AR Dept
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