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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

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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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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