PEEC releases guidance on attest client association, simultaneous employment

The AICPA Professional Ethics Executive Committee (PEEC) has released the following new guidance in the AICPA Code of Professional Conduct:

• A new definition of “simultaneously employed or associated” (ET §0.400.49); and
• A new interpretation, “Simultaneously Employed or Associated With an Attest Client” (ET §1.275.005).

Members should adhere to the new prohibitions and exceptions outlined in the guidance and comply with the reporting requirement when considering employment or association with an attest client.

Reporting requirement

The new interpretation includes a reporting requirement triggered by a member’s intent to accept an attest client’s offer of employment.

The effective date for the changes is Sept. 15, 2026.

Prohibitions and exceptions

The new interpretation prohibits covered members from any simultaneous employment or association with an attest client and prevents any partner or professional employee from holding a key position at an attest client. There are exceptions for independent contractors and specific situations. In other instances, the application of the “Conceptual Framework for Independence” interpretation is appropriate.

The changes aim to balance the prohibition of simultaneous employment and association by covered members and restrictions for other partners and professional employees, while allowing for the evaluation of threats to independence using the conceptual framework in other instances.

The previous version of the interpretation became part of the AICPA Code of Professional Conduct more than 20 years ago, before the advent of the gig economy. To keep pace with current work practices, PEEC revisited the guidance as part of its most recent strategy and work plan.

Upcoming related nonauthoritative guidance

In the coming months, the AICPA Professional Ethics Division will release a document outlining PEEC’s basis for conclusions on this project. The division will also release nonauthoritative guidance to:

• Address scenarios involving volunteers and independent contractors; and
• Provide direction when a member is applying the conceptual framework to scenarios involving factors such as management responsibilities.

— Kelly D. Mullins is the communications manager for the AICPA Professional Ethics Division. To comment on this article or to suggest an idea for another article, contact Neil Amato at Neil.Amato@aicpa-cima.com.