What a CPA records before AI uses return data
A 7216 consent form is the taxpayer's written permission before a tax return preparer uses or discloses return information for a purpose the law does not already allow.
First-party account. Our own tax practice runs on Precision AI OS. A person was in the loop for less than five minutes per return. Not a client result.
When does a section 7216 consent apply to AI?
The statute Knowing or reckless misuse: criminal.
Consent First, unless an exception applies.
Form 1040 Mandatory language since 2014.
Duration One year if blank.
How a firm records an IRS 7216 consent
The CPA classifies each job before any model reads return data.
Classify the step Preparation, use, or disclosure.
Split use and disclosure A separate consent each.
Match the form Form 1040 follows 2013-14.
Record the signature Date, copy, and duration.
Hold until current No consent, no processing.
The AI flags gaps. The CPA classifies.
Classification and the client form stay with the CPA.
AI prepares Lists the return data read.
CPA decides Preparation or a consent event.
AI prepares Flags missing signatures or dates.
CPA decides Whether the form fixes it.
AI prepares Holds jobs without consent.
CPA decides Request, narrow, or keep manual.
AI prepares Logs who released the hold.
CPA decides Names who may release it.
Illustrative consent paragraph, not a form
Invented names Not the mandatory 2013-14 language.
Input Jordan Example's 2025 wage figures.
Output Draft use, firm workspace only.
Note Real consents need mandatory statements.
Where section 7216 consent status has to live
Keep it with the client, not in a side spreadsheet.
Taxpayer name as signed.
Return type and form.
Named recipient or use.
Signature, date, copy.
Duration, or one-year default.
Who may release holds.
Refusals recorded as stops.
Controls before return information moves
Each client's return stays separate.
AI never signs a consent.
Systems that hold consent status
Tax software, portal, practice management.
This page is a plain-English summary for firm planning. It is not tax advice, not legal advice, and not a consent your client can sign.
Questions
Do we need a section 7216 consent just to prepare the return?
No. Under Revenue Procedure 2013-14, engaging a preparer to prepare the return needs no consent.
Can one 7216 consent form cover every AI use we might try this year?
No. Each use or disclosure has to be identified specifically, not as AI in general.
How long does a 7216 consent last?
The period it states. If it states none, the regulation's default is one year from the date of signature.
Who may release a return to the model after the client signs?
A person the firm names, not the drafter. The CPA owns the classification. The system records the release.