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Compliance tool §7216

§7216 consent template generator

Select your AI vendors, the client's jurisdictions, and the use mode. The tool stitches in the Rev. Proc. 2013-14 §5.04 mandatory language, the §301.7216-3 content requirements, vendor-specific data-residency disclosures, and California / New York state overlays. Output as text, Word document, or PDF.

  1. 01

    Firm and preparer

    Required for the engagement header. PTIN is optional and appears only in the audit-trail metadata.

  2. 02

    Client (taxpayer)

    Per §301.7216-3(a)(3), the consent must name the taxpayer. Spouse signature block is included in the output for joint returns.

    Filing category
    Categories of tax return information to disclose

    §301.7216-3(a)(3)(i)(C) requires the consent to describe the specific tax return information being disclosed. Defaults reflect the typical scope for a Form 1040 individual return; uncheck any category that doesn't apply to this engagement.

  3. 03

    Client jurisdiction

    Select every state in which the client has filing or residency exposure. California and New York add state-specific overlays.

    State jurisdictions
  4. 04

    AI service providers used

    Each named vendor appears in the consent with its legal entity, data residency, and retention disclosure. Consumer-tier LLMs (ChatGPT Plus, Claude Pro, free Gemini) are intentionally omitted — those tools are not §7216-defensible regardless of consent.

    AI-native tax tools (CLEAN)
    General-purpose LLMs — enterprise tiers (CLEAN)
    Stack-vendor bundled AI (CLEAN)
    Document intake — exception-tier (EXCEPTION)
  5. 05

    Use mode, effective date, duration

    The use mode populates the "in connection with the preparation of" clause. Duration defaults to a single engagement; §301.7216-3(b)(5) caps unspecified consents at one year from signature.

    AI use mode
    Consent duration

Why this tool exists

Most AI-vendor §7216 consent drafts circulating in practitioner forums omit the Rev. Proc. 2013-14 §5.04 mandatory language — which means they're not valid §7216 consents even when they satisfy the §301.7216-3 content requirements. The AICPA Annual Tax Compliance Kit has §7216 sample forms but no AI-specific template. Tom Gorczynski's canonical analysis outlines the legal framework but does not publish a vendor-named template.

This generator fills that gap: a configurable consent naming the specific AI vendor, with state-specific rider language for California and New York, the §5.04 boilerplate verbatim, and an audit-trail block ready for the firm's WISP file. Practitioners adapt the output to their engagement and route through their own legal review before client signature.

What this tool does not do

It does not constitute legal advice. It does not substitute for a §7216 review by qualified counsel. It does not cover state-board rules beyond California and New York. Consumer-tier LLMs (ChatGPT Plus, Claude Pro, free Gemini, Perplexity Pro consumer) are intentionally absent from the vendor list — those tools are not §7216-defensible regardless of consent. Outputs are drafts; review every named vendor and data class against your engagement before client signature.

Background reading:  Section 7216 AI consent — the rules and the template  ·  §7216 regulation reference  ·  Companion: Circular 230 §10.22 checklist