AI HUB
Welcome to the CCAB AI Hub.
On this hub, you will find a draft Statement to the Accountancy Profession on the Ethical Use of Artificial Intelligence and six draft AI Case Studies which have been produced by the CCAB Ethics Group.
Please provide your feedback on these resources by filling in the short survey after each document.
In addition, you will find a summary of the relevant provisions of the IESBA Code, and links to useful resources produced by the CCAB Member Bodies.
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Draft CCAB Statement to the Accountancy Profession on the Ethical Use of Artificial Intelligence
This draft statement was created to remind professional accountants of their ethical obligations when developing, deploying or using artificial intelligence (“AI”) tools in the course of their professional activities.
In the interests of transparency and professional integrity, CCAB discloses that AI tools were used, alongside human expertise and professional judgement, in the preparation of this Statement.
Responsibility for the content, conclusions and judgements expressed rests entirely with CCAB.
This disclosure reflects a core principle set out in this guidance: that while AI tools may assist professional accountants increasingly in their professional work, the use of such tools does not diminish the personal responsibility or accountability of the professional accountant for that work.
1. Introduction, Purpose and Scope
1.1 Professional accountants are practising in a period of rapid technological change. AI tools and systems are now widely used across audit, accountancy, tax, finance, governance, risk and assurance activities.
1.2 These technologies offer significant potential and opportunities to enhance efficiency, insight, quality and effectiveness. However, they also give rise to complex ethical risks that are novel in scale, speed and opacity.
1.3 This Statement provides guidance to professional accountants on navigating the ethical risks associated with the development and use of AI tools and systems, including Generative AI and autonomous AI agents. It builds upon the International Code of Ethics for Professional Accountants (including Independence Standards) issued by the International Ethics Standards Board for Accountants (“IESBA”) (“the IESBA Code”).
1.4 This Statement applies to all professional accountants, whether in public practice or business, and covers the entire AI lifecycle from development and procurement to deployment and monitoring.
2. Ethical risks associated with the development and use of AI
2.1 The use of AI tools may create, exacerbate or obscure ethical risks. These risks may arise from the design of AI tools and systems, the data on which they are trained, or the manner in which they are deployed. Such risks require robust and proactive management by professional accountants.
2.2 Commonly identified risks include:
2.3 The potential for these risks to crystallise increases where AI tools are used at scale, at speed, or with limited human oversight.
2.4 As such, there is a need to exercise rigorous professional judgement when using AI tools and systems, and to apply an Inquiring Mindset (including the exercise of professional scepticism, in audit and assurance related matters) when relying on their output. Professional accountants are reminded that they cannot abdicate responsibility for outputs produced by their use of AI tools and systems.
3. The IESBA Code and the fundamental Principles
3.1 The Codes of Ethics of each of the CCAB member bodies are derived from the IESBA Code. The IESBA Code applies fully to the development and use of AI tools and systems, and their outputs.
3.2 Professional accountants are reminded of their obligation to act in the public interest and to comply with the five fundamental principles set out in the Code: Integrity; Objectivity; Professional Competence and Due Care; Confidentiality; and Professional Behaviour.
4. Application of the fundamental principles to use of AI
4.1 The principle of Integrity requires professional accountants to not be associated with information that is false, misleading or produced recklessly, or which omits or obscures required information (where to do so would be misleading).
4.2 This applies where such information is generated or assisted by AI tools. As such, professional accountants should be transparent with clients about the use of AI tools on client engagements and ensure that AI-generated reports do not contain materially false or misleading information. Professional accountants should not “recklessly” associate themselves with AI outputs without adequate validation.
4.3. When a professional accountant becomes aware that they have been associated with false, misleading or recklessly produced information, the Code requires them to take steps to be disassociated from that information. Professional accountants should therefore ensure that AI systems they use allow for contestability and redress.
4.4 The principle of Objectivity requires professional accountants to avoid bias, conflicts of interest and undue reliance on automated outputs, and to maintain an inquiring mind when using AI tools. This requires scrupulous checking of AI-quoted sources to mitigate automation bias. It also requires an awareness of the potential impact on how prompts entered into an AI tool are framed: professional accountants should ensure that they do not enter prompts which are designed to produce biased or unfair outcomes
4.5 The principle of Professional Competence and Due Care requires professional accountants to maintain a continuing awareness of technology-related developments. Professional accountants must equip themselves with the skills to use AI tools and systems effectively and ethically, ensuring that clients receive services based on current technical standards and an understanding of AI’s inherent limitations. This includes being able to explain to the client, any material limitations on the use of the tool or the outputs produced.
4.6 The principle of Confidentiality requires professional accountants to ensure that appropriate safeguards are in place across the full data lifecycle, including where information is input into, processed by, or retained within AI systems. Client or any sensitive data should never be input into an AI tool without specific consent, particularly where the tool may retain data for training purposes; or use of the tool might result in the data entering into the public domain.
4.7 The principle of Professional behaviour requires professional accountants to comply with applicable laws and regulations (including AI-specific regulation); behave in a manner consistent with the profession’s duty to act in the public interest; and avoid conduct that may discredit the profession. Compliance with this principle includes ensuring that use of AI complies with relevant laws, such as those governing data protection and intellectual property. It also includes ensuring that AI generated outputs have been fully checked and validated before submitting them to a Court or placing them in the public domain, or publication in circumstances where there is the potential for others to rely on the contents of such documents.
5. Applying the conceptual framework:
Threats and Safeguards
5.1 Professional accountants are required to apply the conceptual framework to identify, evaluate and address threats to compliance with the fundamental principles arising from AI use.
5.2 Such threats may include:
5.3 Potential Safeguards include putting in place robust internal controls, third-party assessments of AI functionality, and comprehensive staff training on AI ethics and prompt engineering.
5.4 Where threats cannot be eliminated or reduced to an acceptable level through safeguards, the professional activity must be declined or discontinued.
6. Responsible AI
6.1 Responsible AI refers to the development and use of AI systems that are lawful, ethical, transparent, accountable and robust. This includes adopting an “ethics by design” approach to the development and implementation processes; establishing clear ethical and business use guidelines; and ensuring that AI systems are used to enhance, not replace, professional judgement.
6.2 Matters to consider include:
6.3 Professional accountants have a key role in supporting Responsible AI through governance, risk management, assurance, documentation and ethical leadership.
7. Public Interest AI
7.1 The IESBA Code states that:
“In acting in the public interest, a professional accountant considers not only the preferences or requirements of an individual client or employing organization, but also the interests of other stakeholders when performing professional activities”.
7.2 Acting in the public interest therefore requires professional accountants to consider the broader societal impacts of AI use, including fairness, discrimination, and trust in financial and corporate information.
7.3 Decisions about AI use should not be based solely on efficiency or commercial considerations.
7.4 Professional accountants should advocate for AI systems that are fair, accountable, and transparent. This involves challenging vendors to provide “model cards” that specify risks and biases, and ensuring AI use does not propagate disinformation or fraud.
8. Other relevant principles and Frameworks
8.1 In addition to the IESBA Code, professional accountants should have regard to relevant international Responsible AI principles, AI governance standards and national frameworks.
8.2 These frameworks complement, but do not replace, professional ethical obligations.
9. The EU Artificial Intelligence Act
9.1 The EU Artificial Intelligence Act establishes a risk-based regulatory framework applying to providers and deployers of AI systems whose outputs are used in the European Union (“EU”)
9.2 Professional accountants practising in, or doing business with, the EU should familiarise themselves with the Act and associated Codes of practice and consider its implications for their professional activities and advice. Relevant sections of the Act include: the risk-based classification of AI systems; obligations on providers and deployers; transparency requirements; human oversight expectations; AI literacy obligations; and enforcement and penalties.
Examples of matters to consider include:
10. Ethical Considerations in the use of AI Agents
10.1 The use of AI agents, which are capable of acting with limited human intervention raises heightened ethical concerns, including reduced human control and unclear accountability.
10.2 The use of AI agents can automate complex workflows like real-time fraud detection or tax optimization. However, professional accountants must ensure that any AI agents operate within a “constrained autonomy” framework defined by the professional accountant, who should retain clear human responsibility for their use and effective oversight.
10.3 Matters to consider include:
10.4 Where an AI agent is representing the professional accountant at a meeting or in a public setting, care should be taken to ensure that AI agents do not beach the principles of professional behaviour or act in a manner likely to discredit the profession.
11. Practical Guidance for Professional Accountants
11.1 Professional accountants are reminded of the importance of achieving and maintaining an adequate level of AI proficiency and understanding of the potential, capabilities and limitations of AI tools in their professional activities.
11.2. Professional accountants should be transparent about their use of AI tools and systems, and reliance on AI generated outputs. In doing so, they should exercise professional judgement, apply professional scepticism; and document judgements and safeguards.
11.3. Professional accountants should remain vigilant about the need to protect confidential information when using AI tools.
11.4 Mindful of the requirement to act in the public interest, professional accountants should challenge inappropriate use of AI tools, and escalate ethical concerns where required.
11.5 Practical Tips for using AI tools and systems ethically include:
The IESBA Code requires professional accountants to encourage and promote an ethics-based culture in their organisations; and to exhibit ethical behaviour in their dealings with those with whom they have a professional or business relationship. The best way to ensure that professional accountants use AI ethically, is to ensure that they have an ethical culture in place in their organisations
Further Resources
Professional accountants are encouraged to refer to guidance and resources issued by CCAB member bodies, IESBA, the International Federation of Accountants, and relevant regulators on the ethical and responsible use of AI.
FEEDBACK SURVEY
We want your feedback on the draft CCAB Statement to the Accountancy Profession on the Ethical use of AI!
Please take this short survey:
FAQs
The statement was produced with the assistance of AI.
A range of AI tools were instructed to use the CCAB Statement on the Use of Sanctions as a template, and provided with links to the IESBA Code, and resources produced by professional accountancy bodies, including IFAC and the CCAB member bodies.
The AI tools were also provided with an initial draft produced by the CCAB Ethics Group.
The AI tools were then instructed to produce a draft statement to the profession.
A composite draft was used, using elements from the various drafts produced by different AI tools (including repeating the prompts used)
The composite draft was then refined and quality assured by members of the CCAB Ethics Group.
The primary concern of the CCAB Ethics Group is to ensure that the profession engage with the statement and think about the issues raised.
We considered that the use of AI, to generate a statement about the ethical use of AI, would generate engagement and discussion.
How did the CCAB Ethics Group ensure the accuracy, reliability and relevancy of the draft statement?
The AI tools were directed to references produced by IESBA, the International Federation of Accountants, and to resources produced by each of the CCAB Member bodies.
The draft statement was quality assured by the CCAB Ethics Group and by technical specialists in each of the CCAB member bodies before publication.
The statement is presented as a draft for engagement and consideration by the profession. Professional accountants are encouraged to provide their comments on the draft to improve the quality of the document before it is finalised.
International code of ethics FOR Professional Accountants – Provisions relating to the use of AI and technology
Duty to act in the public interest
Section 110.A1(e) and R115.1(b) emphasise that professional accountants should behave in a manner that is consistent with the profession’s responsibility to act in the public interest
“Having an inquiring mind”
Section 120.5 A1 clarifies that “having an inquiring mind” is a prerequisite for obtaining an understanding of the known facts and circumstances required for the application of the conceptual framework.
Section 120.5.A1 (a) and (b) set out the two elements of “having an inquiring mind”. These are: considering of the source, relevance and sufficiency of information obtained, as well as being open and alert to a need for further investigation or other action.
Strength of Character to Act Appropriately
Section 111.1 A1 requires professional accountants to have “the strength of character to act appropriately, even when facing pressure to do otherwise or when doing so might create potential adverse personal or organisational consequences.”
Section 111.1 A2 defines “acting appropriately” as: (a) Standing one’s ground when confronted by dilemmas and difficult situations; or (b) Challenging others as and when circumstances warrant, in a manner appropriate to the circumstances.
Objectivity
In section R112.1 , the definition of the fundamental principle of “Objectivity” highlights the risks of technology impairing the objectivity of a professional accountant.
Section 120.12 A2 includes “automation bias” in the list of examples of bias to be aware of in the exercise of professional judgment.
Professional Competence and Due Care
Section 113.1 A3 provides that “maintaining professional competence requires a professional accountant to have a continuing awareness and understanding of technical, professional, business and technology-related developments relevant to the professional activities undertaken.” The section highlights that a professional accountant should achieve a level of understanding “relevant to the activities undertaken…”
Section R113.3 requires professional accountants to explain the implications of limitations inherent in their professional activities to clients. Section 113.1.A3 confirms that this includes limitations related to technology.
Confidentiality
Section R 114.1.A1 emphasises that to maintain the confidentiality of information, a professional accountant must take “appropriate action” “…in the course of its collection, use, transfer, storage or retention, dissemination and lawful destruction” (i.e., throughout the entire data governance life cycle.)
Section R114.2(d) emphasises that a professional accountant is not able to use or disclose information, which is subject to the duty of confidentiality, even where that information has become publicly available (either properly or improperly).
Section R114.2(b) clarifies that the prohibition on the improper use of confidential information extends beyond using it for the personal advantage of the professional accountant. The prohibition includes using such information for the advantage of the professional accountant’s firm or employing organisation, or a third party.
Section R114.3 provides an exception to paragraph R114.2 by detailing the specific conditions under which it is possible to use or disclose confidential information: “(a) there is a legal or professional duty or right to do so; or (b) this is authorized by the client or any person with the authority to permit disclosure or use of the confidential information and this is not prohibited by law or regulation.
Using the output of technology
Where professional accountants intend to use the output of technology in preparing and presenting information, section R220.8 requires them to use their professional judgement in determining the appropriate steps to take. This is to ensure that their responsibilities in relation to such information are properly discharged.
Section 220.8 A1 sets out factors for professional accountants to consider in determining whether reliance on the output of technology is reasonable. These factors include:
- The employing organisation’s or firm’s oversight of the design, development, implementation, operation, maintenance, monitoring, updating or upgrading of the technology.
- The controls relating to the use of the technology, including procedures for authorizing user access to the technology and overseeing such use.
- The appropriateness of the inputs to the technology and decisions made by individuals using the technology.
Section 220.12 A4 stipulates that when a professional accountant is using the work of others or the output of technology, they should consider whether they are in a position within the employing organisation to obtain information in relation to the factors necessary to determine whether such use is appropriate.
There are equivalent provisions for accountants in public practice-section R320.11; 320.11.A1 and 320.12.A1.
Promoting ethical culture
Section 200.5A3 requires professional accountants in business, to encourage and promote an ethics based culture in the organisation and to exhibit ethical behaviour in dealings with individuals with whom, and entities with which, they or the employing organsiation has a professional or business relationship. This is to the extent that they are able to do so, taking into account their position and seniority in the organisation.
Section 300.5.A2 requires professional accountants in public practice to encourage and promote an ethics-based culture in the firm and to exhibit ethical behaviour in dealing with individuals with whom, and entities with which, they or the firm have a professional or business relationship. This is to the extent that they are able to do so, taking into account their position and seniority in the firm.
Section 120.13A2 clarifies that leaders and those in managerial roles have a role in promoting the importance of the ethical values of the organisation. Section 120.13 A3 reminds individual professional accountants of their role in promoting ethical behaviour and culture in their organisation, taking into account their position and seniority.
Auditor independence
Section 400.21 A1 provides that when technology is used in performing a professional activity for an audit client, the prohibitions on assuming management responsibility for that client apply, regardless of the nature or extent of such use of the technology.
Draft CCAB AI Case Studies
These draft case studies were developed by the Consultative Committee of Accountancy Bodies (CCAB). They illustrate how the codes of ethics of the CCAB bodies can be applied by professional accountants facing ethical dilemmas involving artificial intelligence (AI) technologies.
These case studies are fictional scenarios intended to highlight potential ethical dilemmas accountants may face when engaging with AI.
The scenarios presented, while illustrative and designed for discussion, draw inspiration from real-world applications of AI in the accounting profession.
The scenarios are not intended to be detailed accounts of specific real events but are informed by the types of tasks and challenges emerging from AI adoption in practice.
The scenarios are not intended to cover every possible circumstance, but instead outline key principles and issues that should be considered when attempting to identify, evaluate and address ethical threats.
The CCAB Ethics Group welcomes comments from the profession on the draft case studies and how they can be improved; as well as suggestions for additional case studies. The aim is to produce a bank of ethical resources for the profession, dealing with practical issues encountered by the profession when using AI tools and systems.
Consideration of these case studies will involve the application of the five fundamental principles and the conceptual framework, both of which are set out in the Codes of Ethics of the respective CCAB Bodies.
Fundamental Principles
The conceptual framework approach focuses on identifying, evaluating and addressing threats to compliance with the fundamental principles.
The Professional Accountant’s Responsibility
All members and registered students of CCAB bodies have a responsibility to behave professionally and ethically at all times. When encountering ethical dilemmas related to artificial intelligence, professional accountants should apply the conceptual framework approach to identify, evaluate and address threats to the fundamental principles.
The case studies are intended to assist professional accountants in using these ethical decision making tools in the Code, to navigate the ethical dimensions of AI use and adoption.
DISCLAIMER
It is the duty of all professional accountants to familiarise themselves fully with the requirements set out in the Code of Ethics produced by their professional body; you should not rely on summaries of the Code.
The case studies (including analysis of issues and suggested recommendations) are not intended as legal or professional advice, and should not be treated as such.
The CCAB is not able to give tailored advice on specific ethical queries and does not do so.
Should you require advice on a specific ethical issue (including issues which by co-incidence may be similar to those identified in one of the case studies), you should contact your professional body for advice.
You may also wish to obtain legal advice which is tailored to your specific individual circumstances.
The CCAB does not accept any liability for any loss or damage of any kind (howsoever caused) which may arise from reliance on the information and material in these case studies.
Your use of the material and information set out in the AI Hub and in these case studies is at your own risk.
How were the draft CCAB AI Ethics case studies produced
An analysis of anonymised usage data from AI tools, categorised using the U.S. Department of Labour’s Occupational Information Network (O*NET), identified key accounting-related tasks where AI is being explored.
These include areas such as developing, implementing and documenting accounting systems using current technology; preparing and analysing financial statements and records; evaluating financial reporting systems and making recommendations for changes; maintaining current knowledge of standards, policies and tax code changes; and compiling financial reports.
An AI tool was instructed to have regard to these use cases and the IESBA Code, and to produce some illustrative case studies. AI tools were also used to examine human drafted case studies and to analyse potential ethical issues involved and draft potential responses to these issues.
The case studies were refined and quality assured by the CCAB Ethics Group, and those selected are intended to encompass a broad range of accountancy practice.
The case studies are intended to assist professional accountants to in using these ethical decision making tools in the Code, to navigate the ethical dimensions of AI use and adoption.