IESBA issues snapshot on the ethical implications of using technology, including AI

The International Ethics Standards Board for Accountants (IESBA) has issued a snapshot on the ethical use of technology, including Artificial Intelligence (AI). A snapshot is a short, non-technical overview of an IESBA project or initiative. Because the ICAS Code of Ethics is substantively based on the IESBA Code, the snapshot is relevant to CAs.

IESBA recognises that technology creates major opportunities, but it can also increase existing ethical and independence risks. Technology can challenge professional judgement, introduce bias, obscure accountability and potentially create new threats to independence. The question for the profession is no longer whether to use these tools, but how to do so responsibly — anchored in ethics and independence. Technology is among IESBA’s top strategic priorities because it cuts across every aspect of professional conduct, including professional competence and due care, integrity, objectivity, confidentiality and independence. It also has key implications across the business and wider societal environment.

The Snapshot makes clear that the International Code of Ethics for Professional Accountants’,, including International Independence Standards (the IESBA Code) applies to the use of technology – regardless of the tools or technologies involved.  The conceptual framework provides a structured way to identify, evaluate, and address ethical threats in any context, including those linked to technology. When applying the conceptual framework, professional accountants must have an inquiring mind, use professional judgement, and consider what a reasonable and informed third-party would conclude. If a threat cannot be eliminated or reduced to an acceptable level, the accountant may need to decline the engagement, 

IESBA notes that although technology, including AI may challenge the Code, it does not break it. Where ethical qualities such as professional judgement, accountability, and culture are weak, technology increases risks and might also create new ones. Where these qualities are strong, technology can help strengthen trust. The Code is principles-based, which means it is designed to withstand the pace of technological change.

IESBA’s approach to the ethical implications of technology

As set out below, IESBA has adopted a structured, three-pillar approach to address the ethical implications of technology:

1. Keeping the Code fit for purpose: IESBA has made principles-based updates to its Code to make it clear that technology is a source of ethical risk, and to support professional accountants manage those risks. These revisions became effective in the ICAS Code of Ethics from 1 January 2025.
2. Continuous horizon scanning: IESBA has established a standing Technology Expert Group to monitor emerging developments, including AI and agentic AI, digital assets, cybersecurity, and quantum computing.
3. Supporting the profession: IESBA has been developing practical, non-authoritative guidance and carrying out targeted outreach to help professionals understand and apply the Code in technology-related contexts.

We also encourage CAs to contact us if they identify any ethical threats or implications of using AI that they do not believe that the ICAS Code of Ethics covers.

IESBA technology related revisions to the Code

IESBA’s technology-related revisions to its Code (effective in the ICAS Code of Ethics from 1 January 2025) strengthened the Code for an increasingly digital world. They built on earlier changes relating to the role and mindset of a professional accountant and the provision of non-assurance services to audit clients. The non-assurance services provisions do not apply in the UK as auditors are required to comply with the FRC’s Ethical Standard but the FRC does not believe that its requirements are any less demanding. The above revisions to the ICAS Code of Ethics are principles-based and technology-agnostic, so apply to all technologies and can remain useful as technology evolves. to withstand the continuing pace of change. The key changes impacted:

• Professional competence and due care: Professional accountants must understand, explain, and evaluate the technology they use, including keeping pace with technology-related developments relevant to their professional activities. Relying on unclear or unexplained outputs is not acceptable. AI is not responsible for the output; this must always be remembered.
• Inquiring mind: In relation to role and mindset, having an inquiring mind became a mandatory requirement when applying the conceptual framework. Accountants need to understand the source and relevance of inputs, and the sufficiency of technology outputs for the intended purpose. It applies to all professional accountants regardless of the activity undertaken.
• Use of technology outputs: New explicit requirements apply whenever a professional accountant uses technology outputs — whether internally developed, purchased, or third-party. Accountants must assess fitness for purpose, understand limitations and assumptions, evaluate data quality and potential bias, and determine the appropriate extent of reliance.
• Automation bias: In the context of role and mindset, automation bias is the tendency to favour technology-generated outputs even when other information raises questions about their reliability. The 2025 Code names this as a bias that can impair objectivity and the proper exercise of professional judgement. The Code requires accountants to be alert to this and other biases, and professional responsibility cannot be delegated to a machine.
• Complex circumstances: The Code includes guidance on managing complexity, especially where uncertainty, assumptions and interdependent factors overlap. Digitalisation is making these situations more common. Professional accountants must explain key uncertainties to their organisation, firm or users of their work, and stay alert to changes in facts and circumstances.
• Confidentiality: Confidentiality obligations were extended to cover the full data lifecycle: collection, use, transfer, storage, dissemination, and lawful destruction. The use of client data for purposes such as AI model training requires proper authorisation, with clear boundaries around consent. These need to be adhered to.
• Independence: The independence standards were strengthened to address risks specific to technology-enabled services including self-review threats, assuming management responsibility and commercial dependencies that can arise when technology is used to deliver professional services to audit or assurance clients.

Current position

The technology landscape continues to evolve rapidly and continuously, and IESBA has decided not to make further Code changes for now. The strength of the IESBA Code lies in its principles-based approach. It sets out principles that guide professional conduct rather than detailed rules for specific circumstances. If changes are made to respond to each development in technology-based tools, this would risk making the Code fragmented, difficult to apply, and quickly outdated. 

We support the current stance of IESBA, which is: “Rather than adding to the pace of change the profession is already managing, the priority is to allow the 2023 revisions time to be adopted and implemented, supported by practical guidance as technology continues to be successfully incorporated into professional activities.”

IESBA – practical guidance

IESBA is currently developing the following practical guidance to support the profession in applying the Code in technology-related contexts and two non-authoritative guidance materials (NAMs) are planned:

• An overarching Technology NAM (planned Q3 2026). This will explain how common features of emerging technologies can stress the Code’s fundamental principles and how the conceptual framework can be applied across the different technologies.
• AI-Specific NAM (planned Q4 2026). Developed with input from the IESBA Technology Expert Group, this publication will provide targeted practical support on the ethical challenges most commonly associated with AI use by professional accountants.

In addition, IESBA has already published:

• Ethical Leadership in a Digital Era — a joint publication with the Japanese Institute of Certified Public Accountants (JICPA) (2022) that explains the application of the Code to technology-related situations in practice.
• Practical Guidance for Auditors in Technology-Related Scenarios — a joint publication with the Accounting Professional and Ethical Standards Board, Australia (APESB) (2023) that explains the application of the Code's conceptual framework to technology-related independence scenarios.
• The Decoding Ethics podcasts, featuring monthly episodes on technology themes, addressing current topics such as AI and agentic AI, quantum computing, automation bias, education efforts, and human judgement in a digital age.

IESBA Technology Working Group and Technology Expert Group

To keep up with technology developments, IESBA has established a Technology Working Group and a Technology Expert Group, the latter of which includes eight practitioners with hands-on experience in current and emerging technologies, who regularly monitor and identify issues that may affect the profession. 

At the March IESBA Board meeting, the IESBA considered and supported the TWG’s draft work plan for the first half of 2026. The TWG work plan focuses on raising awareness of the technology-related revisions to the Code that became effective in the ICAS Code of Ethics from 1 January 2025. It also includes developing new guidance on applying the Code’s principles to emerging technologies such as AI, and sustaining momentum through ongoing environmental scanning and collaboration with the International Auditing and Assurance Standards Board (IAASB) to keep guidance current.

Recent highlights of IESBA’s Technology Expert Group include:

• AI and agentic AI: Organisations are increasingly deploying AI in every aspect of their operations, but governance and oversight mechanisms lag behind adoption. Agentic systems, capable of autonomous execution and agent-to-agent interactions, raise additional risk concerns, including critical questions about traceability, human oversight, and accountability.
•  “Shadow AI”: employees independently using AI tools without organisational approval is a growing and underappreciated risk across the profession.
• Digital assets and stablecoins, AI-assisted cybersecurity threats, and quantum computing are also being monitored as areas of emerging relevance.

Other resources

We would also highlight four thought leadership papers which were published jointly by the Chartered Professional Accountants of Canada (CPA Canada), ICAS, and the International Federation of Accountants (IFAC) following an exploratory paper and global roundtable event – "Ethical Leadership in an Era of Complexity and Digital Change" – jointly hosted by ICAS, CPA Canada and IFAC in February 2021. These can be viewed at: CPA Canada ICAS IFAC Technology Papers

In addition, ICAS has published articles covering certain ethical matters relating to the use of AI:

• CCAB publishes podcasts on AI-related ethics issues
• Beware of the risk of bias when using AI
• AI unlocked: A practical guide to generative AI
• CA Magazine: Ethical use of AI