AICPA PEEC Releases Guidance on Attest Client Association and Simultaneous Employment
The AICPA Professional Ethics Executive Committee (PEEC) recently released new guidance in the AICPA Code of Professional Conduct. The guidance includes a new definition of “simultaneously employed or associated” (ET §0.400.49) and a revised interpretation, “Simultaneously Employed or Associated With an Attest Client” (ET §1.275.005).
The new interpretation includes a reporting requirement that will be triggered by a member’s intent to accept an attest client’s offer of employment.
The interpretation prohibits covered members from simultaneous employment or association with an attest client as well as prevents any partner or professional employee from holding a key position at an attest client. The guidance outlines exceptions for independent contractors and some specific circumstances. In other cases, it will be appropriate to apply the “Conceptual Framework for Independence” interpretation.
The purpose of these changes is 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 via the conceptual framework in other cases.
The effective date for the changes is Sept. 15, 2026.