State CPA Board Disclosure Matrix for Offshore Accounting Engagements

The landscape

How state CPA board rules interact with federal and AICPA requirements

A CPA firm using offshore accounting staff potentially faces three layers of rules:

Federal. IRS §7216 for tax return information disclosure. Federal statute, applies uniformly across all 50 states.
AICPA Code of Professional Conduct. §1.150.040 for third-party service provider disclosure. Binding on AICPA members; most state CPA boards have adopted the AICPA Code (or substantially similar code) as the state standard.
State-specific. Some state CPA boards have additional rules beyond the AICPA baseline – explicit written consent, specific disclosure wording, offshore-specific notification requirements.

Most states follow the AICPA baseline with no additional offshore-specific requirements. A handful have notable additions. This matrix summarizes the current landscape as a starting reference; always verify current state board rules before relying on this information, as state rules change over time.

Big picture takeaway: in the vast majority of states, following AICPA §1.150.040 and obtaining the written disclosure/consent described in our engagement letter addendum satisfies state board requirements. The states with additional specifics are the exception.

The matrix

State-by-state summary (all 50 states)

Research current as of April 2026. Verify directly with the state board before relying on this information for a specific engagement. Rules change; our summary may not reflect the most recent updates.

State	AICPA Code adopted	Additional specifics for offshore engagements
Alabama	Yes	No additional specifics beyond AICPA baseline.
Alaska	Yes	No additional specifics beyond AICPA baseline.
Arizona	Yes	No additional specifics beyond AICPA baseline.
Arkansas	Yes	No additional specifics beyond AICPA baseline.
California	Yes	CBA Article 12 Regulation 54.1 requires specific disclosure of third-party client record custodians. For engagements involving patient data, California Confidentiality of Medical Information Act (CMIA) may also apply.
Colorado	Yes	No additional specifics beyond AICPA baseline.
Connecticut	Yes	No additional specifics beyond AICPA baseline.
Delaware	Yes	No additional specifics beyond AICPA baseline.
Florida	Yes	Florida Board of Accountancy generally follows AICPA; no additional offshore-specific rules published as of research date.
Georgia	Yes	No additional specifics beyond AICPA baseline.
Hawaii	Yes	No additional specifics beyond AICPA baseline.
Idaho	Yes	No additional specifics beyond AICPA baseline.
Illinois	Yes	Illinois Public Accounting Act §23.12 references third-party assistance; state board guidance suggests explicit client consent where offshore preparation is involved.
Indiana	Yes	No additional specifics beyond AICPA baseline.
Iowa	Yes	No additional specifics beyond AICPA baseline.
Kansas	Yes	No additional specifics beyond AICPA baseline.
Kentucky	Yes	No additional specifics beyond AICPA baseline.
Louisiana	Yes	No additional specifics beyond AICPA baseline.
Maine	Yes	No additional specifics beyond AICPA baseline.
Maryland	Yes	No additional specifics beyond AICPA baseline.
Massachusetts	Yes	Massachusetts Board of Public Accountancy follows AICPA Code. Massachusetts Data Breach Notification Law (201 CMR 17.00) may apply to PII handling.
Michigan	Yes	No additional specifics beyond AICPA baseline.
Minnesota	Yes	No additional specifics beyond AICPA baseline.
Mississippi	Yes	No additional specifics beyond AICPA baseline.
Missouri	Yes	No additional specifics beyond AICPA baseline.
Montana	Yes	No additional specifics beyond AICPA baseline.
Nebraska	Yes	No additional specifics beyond AICPA baseline.
Nevada	Yes	No additional specifics beyond AICPA baseline.
New Hampshire	Yes	No additional specifics beyond AICPA baseline.
New Jersey	Yes	New Jersey State Board of Accountancy adopts AICPA Code by reference. Verify current rules on third-party providers.
New Mexico	Yes	No additional specifics beyond AICPA baseline.
New York	Yes	NY State Board for Public Accountancy has published guidance on offshore preparation referencing §7216 compliance. Verify current guidance with the Board.
North Carolina	Yes	No additional specifics beyond AICPA baseline.
North Dakota	Yes	No additional specifics beyond AICPA baseline.
Ohio	Yes	Ohio Accountancy Board Rule 4701-11-07 references third-party service provider use; follows AICPA framework.
Oklahoma	Yes	No additional specifics beyond AICPA baseline.
Oregon	Yes	No additional specifics beyond AICPA baseline.
Pennsylvania	Yes	Pennsylvania State Board of Accountancy generally follows AICPA Code; verify current state board guidance.
Rhode Island	Yes	No additional specifics beyond AICPA baseline.
South Carolina	Yes	No additional specifics beyond AICPA baseline.
South Dakota	Yes	No additional specifics beyond AICPA baseline.
Tennessee	Yes	No additional specifics beyond AICPA baseline.
Texas	Yes	Texas State Board of Public Accountancy Rule §501.75 addresses outsourcing; requires client notification of third-party provider use. Rule §501.76 covers confidentiality.
Utah	Yes	No additional specifics beyond AICPA baseline.
Vermont	Yes	No additional specifics beyond AICPA baseline.
Virginia	Yes	Virginia Board of Accountancy follows AICPA Code adopted by reference. No additional offshore-specific rules.
Washington	Yes	Washington Board of Accountancy has published informal guidance recommending explicit written client consent for offshore preparation engagements.
West Virginia	Yes	No additional specifics beyond AICPA baseline.
Wisconsin	Yes	No additional specifics beyond AICPA baseline.
Wyoming	Yes	No additional specifics beyond AICPA baseline.

District of Columbia follows AICPA Code and has no published offshore-specific additional rules.

States worth extra attention

The five states most often cited for extra offshore rules

If your firm operates in one of the following states, or has clients in them, pay extra attention to state-specific guidance:

California. CBA Article 12 Regulation 54.1 requires specific disclosure of third-party record custodians. CMIA adds additional health data considerations for medical practice engagements.
Texas. Texas State Board Rule §501.75 addresses outsourcing specifically and requires client notification. Rule §501.76 covers confidentiality obligations.
New York. NY State Board has published informal guidance on offshore preparation referencing §7216. Some firms prefer explicit standalone consent beyond the engagement letter.
Illinois. Illinois Public Accounting Act §23.12 references third-party assistance; suggests explicit client consent for offshore engagements.
Washington. Informal state board guidance recommends explicit written consent for offshore preparation engagements.

What to do when state rules are unclear

If your state's offshore-specific rules are unclear or you're operating in multiple states, the defensible approach is: (1) always obtain written client consent following the AICPA baseline, (2) use the most conservative disclosure language from any state where you operate, and (3) document the consent carefully in your engagement records. This satisfies §7216 federally, §1.150.040 ethically, and provides a reasonable defense against any state-specific challenge.

Disclaimer: This matrix is for general reference only and does not constitute legal advice. State CPA board rules are subject to change; the information above reflects research as of the date of publication and may not be current. Always verify with the relevant state board of accountancy and consult qualified counsel before relying on this information.

State CPA board disclosure matrix for offshore engagements.

How state CPA board rules interact with federal and AICPA requirements

State-by-state summary (all 50 states)

The five states most often cited for extra offshore rules

What to do when state rules are unclear

Related resources

State compliance layer sorted – ready to start the engagement.

State CPA board disclosure matrix for offshore engagements.

How state CPA board rules interact with federal and AICPA requirements

State-by-state summary (all 50 states)

The five states most often cited for extra offshore rules

What to do when state rules are unclear

Related resources

AICPA §1.150.040

IRS §7216

Engagement Letter Addendum

State compliance layer sorted – ready to start the engagement.