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Now’s the time to review your accounting firm’s WISP

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Even as tax pros emerge from yet another fall busy season, only to take a breath and prepare for next year, knowing where you stand on data security is a year-round priority. It is at this time, in particular, that you need to give attention to your WISP.

For those still unfamiliar with the concept, a written information security plan is a mandatory, comprehensive document for accountants, CPAs and tax professionals that outlines a firm’s strategy to safeguard sensitive client data from unauthorized access, theft or misuse. Moreover, a well-structured WISP is essential for complying with federal and state regulations — such as IRS requirements (Publication 4557) and the Gramm-Leach-Bliley Act — maintaining client trust and upholding professional credibility.

So, if your WISP is even more than a year old, or perhaps whatever security plan you have is scattered across spreadsheets and emails, then it’s time for a thorough review. I would even go so far as to say an updated and tested WISP is no longer just a compliance checkbox; it is a core element of effective risk management and business resilience.

5 reasons why last year’s WISP may not be enough

  1. Legal compliance: For tax professionals, having a WISP is not optional; it’s a legal requirement. When renewing your PTIN on IRS Form W-12, Question 11 specifically asks you to confirm that you have a WISP in place. Providing a false response is considered perjury and may lead to serious consequences, including PTIN termination or even revocation of your license.
  2. Ransomware and resilience: The threats have evolved and changed. According to a report by Mimecast, the human element is often the primary cause of breaches, and ransomware remains a persistent threat. This underscores the need to prioritize access controls, phishing resilience and regular response rehearsals. Tools alone should not be the focus — your plan must center on people and processes, supported by clear metrics and benchmarks to demonstrate effectiveness.
  3. Mandatory breach notification: If you store or process financial data of customers, the Federal Trade Commission Safeguards Rule now requires you to notify the FTC of any breach within 30 days if the breach has affected more than 500 customers. This change should be reflected in your incident-response section and standard operating procedures.
  4. New tech, new risks: Your business has changed, too. If you have undergone migration to new SaaS platforms, AI adoption, M&A, new data flows, remote hires or fresh third‑party integrations, all these changes affect your cybersecurity requirements and the nature of potential threats. If the WISP does not reflect today’s asset inventory, data classifications and vendor list, it can’t guide today’s risk-mitigating decisions and policies.
  5. Increased expectations: Regulators have raised expectations. NIST Cybersecurity Framework 2.0 has introduced a new governance function and clarified outcomes across risk management, supply chain, and measurement. Even if you don’t want to align with NIST CSF, most customers, auditors and cyber insurers align with it now. Updating your WISP to be in sync with CSF 2.0 lends it authenticity and makes it trustworthy.

What should be in your WISP?

Once you’ve made the move to update your WISP, here are several essential items it should contain and specifically address:

  1. Governance and risk management: Start with accountability and clear oversight. Define who in your firm is responsible for it (or who is engaged by it). Whether it’s leadership, IT (internal or external), legal or HR, they need to set reporting cadences and escalation thresholds. The WISP should also classify data (public, internal, confidential, regulated) and show how risk assessments shape budgets, controls and exception handling.
  2. Information assets and access controls: Your plan must track every asset — endpoints, databases, cloud apps and privileged accounts — and keep this inventory updated. Just as important is access: A phishing-resistant multifactor authentication, and automated joiner/mover/leaver workflows, all reduce risk from both insiders and attackers.
  3. Secure operations and technology use: Security should be built into everyday processes, from code reviews and dependency scans to documented change approvals and rollbacks. With new tools like AI and LLMs, your WISP must outline safe usage policies to protect data and avoid unintended exposure. 
  4. Third-party oversight and incident response: Vendors handling client data must be vetted, monitored and contractually bound to security standards. Your WISP should also detail how incidents are handled — who decides materiality, how regulators like the FTC are notified within 30 days, and how communication is managed. 
  5. Resilience, awareness and continuous improvement: Resilience means tested backups, disaster recovery plans and measurable employee awareness training. A modern WISP tracks security metrics like multifactor authentication adoption and patch compliance, while aligning with standards like ISO 27001 and NIST CSF 2.0 to stay audit-ready.

DIY vs. managed WISP

While some firms try to build and maintain a WISP on their own, this DIY route can be time-consuming and often overlooks evolving regulations or hidden risks. A managed WISP solution, by contrast, brings expert oversight, regular updates and tested playbooks that keep you audit-ready and compliant with IRS and FTC expectations. 

For practices without in-house security expertise, outsourcing WISP management to an experienced, knowledgeable managed service provider can save time, reduce risk and provide confidence that client data is protected to the highest standards.

Protect your organization with a robust WISP

As things hopefully begin to wind down for you this year, right now is the best window to review or construct your WISP. An outdated WISP isn’t just a compliance issue, it’s a business risk. 

Updating it now ensures you’re ready for IRS and FTC requirements, resilient against evolving threats, and positioned to protect the client trust that drives your practice.

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Accounting

SEC’s Semiannual Reporting Proposal Faces Investor Pushback: What CFOs Need to Know

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U.S. Securities and Exchange Commission (SEC)

A proposal from the U.S. Securities and Exchange Commission to potentially shift some public companies away from quarterly financial reporting toward a semiannual model is drawing significant pushback from investors, even as it continues moving through the regulatory process. The debate has direct implications for corporate finance teams, auditors, and the broader transparency of U.S. capital markets.

What the SEC Proposed

According to a summary published by accounting advisory firm Cohen & Co., the SEC issued a proposed rule on May 19, 2026, aimed at simplifying financial reporting requirements for many U.S. public companies. The proposal would potentially reduce the frequency of certain mandatory disclosures from quarterly to semiannual, a structural change that has not been made to core U.S. reporting requirements in decades.

The proposal follows an extended debate within U.S. policy circles, with proponents arguing that reduced reporting frequency could lower compliance costs and free up management time for longer-term strategic planning rather than quarter-to-quarter results management.

Why Investors Are Pushing Back

Comment letters submitted in response to the proposal have been extensive, and according to Cohen & Co.’s review of the public record, investors “appear to be largely opposed” to the shift, viewing frequent interim reporting as a core benefit of U.S. capital markets relative to other jurisdictions.

Accounting and law firms have taken a more measured position, generally urging any changes to remain aligned with the Financial Accounting Standards Board (FASB), whose existing disclosure requirements and guidance are built around a quarterly reporting cadence. A shift to semiannual reporting without corresponding changes to FASB guidance could create friction between SEC filing requirements and GAAP-based disclosure expectations.

Lessons From the U.K. Experience

The debate is not without precedent. The United Kingdom moved away from mandatory quarterly reporting for listed companies in 2014, returning to a semiannual disclosure requirement. According to Cohen & Co.’s analysis, that experience offers a cautionary data point: there was no measurable increase in capital expenditure or R&D investment following the change, while analyst coverage of affected companies declined as reliable interim information became less available — a particular risk for smaller and newly public companies that rely on analyst coverage to maintain investor visibility.

Practical Implications for Finance Teams

Beyond the debate over disclosure philosophy, the proposal carries practical complications. Many companies have debt covenants and credit agreements structured around quarterly financial delivery; a shift to semiannual reporting could require renegotiating those terms. Reduced reporting frequency would also extend the “window of market silence” between disclosures, a factor that governance and investor-relations teams would need to manage carefully to avoid information asymmetry.

Separately, and unrelated to the reporting-frequency debate, the SEC and FASB have continued finalizing more routine updates this year. New Accounting Standards Updates are taking effect for December 31, 2026, fiscal year-ends covering income tax disclosures, credit loss measurement, induced debt conversions, and stock compensation, according to Eide Bailly’s review of 2026 ASU activity. Additional guidance on paid-in-kind dividends and environmental credits is also on the near-term horizon.

What to Watch Next

The semiannual reporting proposal remains in the comment and review phase, and no final rule has been adopted as of this writing. Finance leaders should monitor the SEC’s regulatory agenda for further movement, while treating the current quarterly reporting requirement as the operative standard until any final rule is issued and an effective date is set.

Given the extent of investor opposition documented in the comment file, a full shift to mandatory semiannual reporting appears more likely to result in either a scaled-back compromise or continued study rather than swift adoption — though the SEC’s ultimate direction remains uncertain.

 

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Accounting

AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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