Date posted: 04/05/2026

Submission on use of AI and the Code of Professional Conduct

Draft guidance is timely and a helpful step for registered tax and BAS agents when using artificial intelligence (AI) tools to provide their services.

In brief:

  • AI supports, but does not replace, professional tax judgement
  • More guidance needed on confidentiality and managing third-party AI risks
  • Worked examples will help small practices apply Code obligations to common scenarios

Chartered Accountants Australia and New Zealand (CA ANZ) welcomes draft guidance from the Tax Practitioners Board (TPB) on the use of artificial intelligence (AI) and the Code of Professional Conduct (Code) in exposure draft information sheet, TPB(I) D62/2026.

CA ANZ supports the draft guidance’s focus on professional judgement, verification of AI outputs and practitioner accountability when using AI tools. CA ANZ recommends several targeted improvements to ensure the guidance is clear, actionable and relevant for practices of all sizes.

  • Provide clear, practical advice on managing confidentiality and third-party risks, especially when using external AI chatbots. This should cover model training and data retention.
  • Provide examples and suggested wording to help practitioners obtain informed client permission where client information may be shared with an AI provider,  with a focus on the use of AI features embedded in internal software.
  • Expand the explanations on competency and quality management to include documentation examples and guidance on supervising staff who use AI tools. Reference relevant case law to illustrate real-world application.
  • Include worked examples that illustrate how Code obligations apply in common scenarios. For example, using AI to:
    • summarise steps for a client email and reviewing before sending (low risk)
    • summarise information provided by clients (medium risk)
    • draft tax advice (high risk).

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