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Outsourcing Due Diligence Checklist for Accounting Firms | HelloBooks What to check before sending client work to an outsourcing provider: section 7216 consent, FTC Safeguards Rule contract terms, access, data location.

Checklist · Outsourcing

Outsourcing vendor due-diligence checklist

Before an outside team touches client returns or books, your firm needs answers on consent, security and contract terms. This checklist covers the federal rules that apply and the practical questions behind them.

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Consent and disclosure (section 7216)
Security (FTC Safeguards Rule)
Working arrangements
Ongoing oversight

The two federal rules that drive this

Section 7216 rules decide when you need a client’s consent to share return information; 26 CFR 301.7216-2(d)(1) allows disclosure to another preparer only if that preparer is in the United States. The FTC Safeguards Rule decides how you oversee the provider: 16 CFR 314.4(f) requires you to select capable providers, require safeguards by contract, and assess them periodically.

Keep the evidence

File the completed checklist, the signed contract and the provider’s security answers with your WISP. If something goes wrong, the file shows what you checked and when.

FAQ

Frequently asked questions

Does a US-based outsourcing firm need client consent?
Under 301.7216-2(d)(1), disclosure to a US-located preparer to help prepare the return is permitted without consent, as long as it does not make substantive determinations. Other uses may still need consent.
Is this checklist legal advice?
No. It points to the federal rules; have counsel review your contracts and consents.

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