The December 2019 Journal of Accountancy includes an excellent article, Independence and information system services, by Dan O'Daly on revisions to the "Information Systems Design, Implementation, or Integration" interpretation of the AICPA independence rules. Dan, who serves on the AICPA Professional Ethics Executive Committee's Information Technology and Cloud Services Task Force (along with myself and several others) is a managing director in the independence group at Deloitte. The articles walks the reader through the revisions, the meaning of key terms and why the new interpretation provides the practitioner valuable clarifications.
The new interpretation is not effective until January 1, 2021, but does allow early implementation. Firms performing these services will find that a sooner-rather-than-later approach to implementing the revised rules will allow the firm sufficient time to amend service contracts with attest clients.
