Licensing Historical Business Data for AI: A Guide for Accounting Firms

Start with the work behind the final document

A final financial statement usually omits much of the process that produced it. An internal reconciliation workflow might connect a question, an investigation, a review comment and a resolution. Those relationships can make operating records more informative than a folder of disconnected files. This is an illustration of possible workflow context, not a claim that a buyer wants a particular client engagement.

For a first assessment, describe categories such as internal procedures, engagement coordination, review histories and bookkeeping workflows. Separate the business process from the underlying taxpayer information, financial account details and client documents. A category that looks useful can still be unsuitable because of confidentiality, ownership or contractual restrictions.

Build an inventory without copying client records

The first deliverable can be a simple worksheet describing systems, date coverage, responsible people and exclusions. The FTC recommends understanding what personal information a business holds, where it flows and who has access. Apply that inventory discipline before considering any external transfer. [2]

The following entries are a hypothetical example for an accounting practice. They describe record categories rather than actual client content. Their inclusion in an inventory does not mean they are cleared for licensing.

• Internal knowledge base: procedures from 2021–2025; owner: operations manager; useful context: changes to the month-end process; exclude embedded client examples and externally licensed reference materials pending review.
• Practice-management system: engagement workflow history from 2022–2025; owner: engagement operations lead; useful context: assignment, review and completion steps; exclude client identities, attachments and restricted matter notes pending review.
• Document workspace: internal review procedures and version histories from 2020–2025; owner: IT administrator and practice partner; useful context: how review standards evolved; exclude client workpapers, tax returns and bank details pending review.
• Helpdesk or internal support system: staff process questions from 2023–2025; owner: support lead; useful context: recurring workflow issues and resolutions; exclude employee personal information, credentials and client content pending review.

Resolve rights and confidentiality before discussing an export

A firm’s ability to open a file is not proof that it can license the contents for AI use. Ask qualified legal and privacy advisers to assess ownership, engagement terms, client confidentiality, professional duties and third-party restrictions. The review may identify records to exclude, questions requiring further analysis or reasons to stop entirely.

Keep an exclusion column in the inventory. Identify taxpayer information, account numbers, employee records, credentials, client confidences and material obtained under a third-party license. Avoid treating a general promise to remove names as permission to transfer every record. De-identification is a processing step; it does not by itself answer the separate question of whether the proposed use is permitted.

Describe history and quality without estimating a payout

Years of history are useful to describe precisely. Record the earliest and latest dates for each system, whether migrations created gaps, whether versions are preserved and whether records connect to a recognizable workflow. Five years of inconsistent exports and five years of continuous, well-described activity are different inventory findings. Neither establishes a particular valuation.

Mode says it reviews systems and dates in scope, years of history, record volume and quality, and ownership and access terms before making an offer. It currently identifies accounting firms with ten or more employees as potentially eligible and describes U.S.-based teams with several years of owned operating records as a strong fit. These are program descriptions, not an acceptance decision. Confirm current criteria on the official evaluation page. [1]

Prepare a scope discussion rather than an upload

A useful initial summary states the firm’s size, location, systems and approximate coverage. It can also identify an internal decision-maker and the categories that require exclusion. This gives a potential buyer a clearer basis for discussion without sending raw client records during the initial inquiry.

Mode describes agreeing on systems and date ranges before export, preparing a filtered copy and setting payment terms in a written agreement. The company retains its originals. Its public description also says the agreement defines scope and any exclusivity. Read the actual proposed terms rather than assuming a website summary covers every obligation. [1]

• List the systems and date ranges you are prepared to discuss.
• Name the people responsible for business approval, technical access and rights review.
• Describe quality gaps and exclusions at a category level.
• Keep client records and access credentials out of the initial summary.
• Require written agreement on the scope and applicable terms before proceeding.

Ask questions that make the proposed transaction concrete

The buyer conversation should clarify what the buyer proposes to obtain and what happens afterward. Ask which entities may receive the copy, the intended uses, onward-sharing restrictions and how excluded categories will be handled. Ask how the buyer will address identifiers in context and the possibility of re-identification; removing names alone does not guarantee anonymity.

Also ask about security responsibilities during extraction and processing, retention and deletion obligations, permitted future uses, exclusivity, payment milestones and what happens if the agreed scope changes. Some answers may require contractual terms rather than verbal assurances. Have appropriate advisers review them before deciding whether the proposal fits the practice.

Use a clear decision point

Proceed to an evaluation when you can describe the records and identify who will assess the rights and proposed terms. Pause when ownership is unclear, exclusions cannot be applied reliably or a proposed use conflicts with client commitments. Declining a transaction can be the appropriate outcome.

The FTC’s guidance emphasizes limiting unnecessary personal information, restricting access and protecting information a business keeps. A possible licensing opportunity should not become a reason to accumulate additional sensitive records or abandon appropriate retention requirements. [2] The practical goal is a well-informed decision about a defined set of records, with uncertainty made explicit.