Using EVA under the TPB's AI guidance.
TPB(GS) 55/2026, issued on 22 July 2026, adds no new law. It asks you to stay responsible for the work, get each client’s permission before their information goes into an AI tool, tell them who gets it, where it is stored and that AI is used, check the output, and keep a record of the checks. VibeCFO helps you meet each of those: the client gives the permission themselves when they accept your invite. The TPB approves and endorses no AI provider, VibeCFO included.
Not legal advice. Quotations read on 27 October 2026.
In the TPB’s own words.
The paragraphs that decide how a firm uses an AI tool on client work, quoted from the guidance statement. Read the whole thing on the TPB’s site.
“tax practitioners are still ultimately responsible for the tax agent services they provide to their clients. It is important for tax practitioners to understand the capabilities and limitations of AI tools, and ensure AI outputs are assessed and supplemented by professional judgement, before being relied on.”
“how and where information is being stored and how it is being used by the AI ... the processes in place for the tax practitioner to review the output of the AI before the output is used in professional practice”
“tax practitioners must exercise their own professional judgement when advising clients and should not rely on AI output as a substitute for their own analysis of a client's circumstances.”
“Tax practitioners should verify and review AI generated content for accuracy throughout each step of the workflow and should establish processes to understand and contest AI decisions/outputs. Each of these steps should be documented.”
“whether the tax practitioner checks or reviews the output of the AI tool before purporting to rely on it”
“a third party is any entity other than the client and the tax practitioner.”
“tax practitioners must obtain permission from each client prior to divulging client information to a third party (which can include entering client information into AI models and tools, depending on how these tools are configured and used). When obtaining this permission, it is recommended that the tax practitioner clearly inform the client about the proposed disclosure (including noting to whom and where the disclosure will be made, where data will be stored and whether AI tools may be used).”
“The client permission may be by way of a signed letter of engagement, signed consent, or other communication such as a relevant 'fact find' and consent. A general authority consenting to disclosure to third parties may also be acceptable.”
“Tax practitioners are ultimately responsible for exercising due diligence when using AI tools, including conducting appropriate review of commercial and internally developed or modified AI tools to ensure information will be kept secure and that the requirements of the Privacy Act 1988 (Cth) (Privacy Act) are met.”
“Where the client information involves tax file numbers (TFNs), additional obligations under the Privacy (Tax File Number) Rule 2015 will apply.”
What it asks, and what you have to do it with.
The judgement stays yours: no platform can review work for you. What VibeCFO gives you is the disclosure, the client’s own step, the controls and the facts to put in your file.
| GUIDANCE | WHAT YOU DO | WHAT VIBECFO GIVES YOU |
|---|---|---|
| Paras 8 and 15 | You stay responsible for the work. Use your own judgement, and assess AI output before anyone relies on it. | The numbers EVA returns come from the client's own database, not from the model, so each one can be checked against the ledger it came from. |
| Para 9 | Know how and where information is stored and used by the tool, and how you will review its output. | Where every firm's data is held and where the AI runs, region by region, on the security and subprocessors pages, and the processor terms in the Data Processing Addendum. |
| Paras 16 and 17 | Verify AI content at each step, be able to contest it, and document the checks. | A Pulse acts only when you approve it, and only through the MCPs you have connected. EVA questions and answers are traced. |
| Paras 21 and 23 | VibeCFO and its AI suppliers are third parties. Get each client's permission first, and tell them to whom, where, and that AI is used. | The client invite. Your client accepts VibeCFO's end-user terms before they can sign in, and the platform records the date they accepted. |
| Para 24 | Permission can be a signed engagement letter, signed consent or another communication. | A clause to adapt for your own engagement letter, below. |
| Paras 25 and 26 | Do your due diligence on security and the Privacy Act, and check the TFN Rule where TFNs are involved. | The security page, the subprocessor list and the addendum, and our ISO 27001 status as it stands: in progress, not yet certified. |
| Determination ss 30, 35, 40 | Keep records of the services, supervise the people doing them, and document and enforce your quality management. | Row-level security applied before the query runs, so restricted rows are never selected at all, so staff see only the clients they are given. Infrastructure and administrative actions logged (AWS CloudTrail), database connections audited, and EVA questions and answers traced. |
| TPB(GS) 31/2018 | Ask for a positive, opt-in step from the client, and never imply that all the work is done in Australia. | Accepting the invite is the client's own step. The facts below tell you exactly what to say about where processing happens. |
The invite is where the client says yes.
Paragraph 23 asks for permission before client information goes into an AI tool, and for the client to be told to whom, where and whether AI is used. When you invite a client in as a member, they read that and accept it themselves.
You invite the client
Add the client's workspace and invite the owner, or whoever you deal with, as a member. The invite comes from your firm.
They read what they are agreeing to
Before they can sign in, they accept VibeCFO's end-user terms. The published terms tell them that EVA is AI and can make mistakes, which providers supply the models, that processing may take place outside Australia, that no model is trained on their data, and where the current list of suppliers is kept.
They accept, and it is recorded
Accepting is a step the client takes themselves. The platform records the date they accepted, against their membership of your firm's platform.
Your letter says the same thing
Paragraph 24 lists the engagement letter first. Put the clause below in yours, so the permission sits in your engagement as well as in the invite.
“even in the context of a general disclosure, tax practitioners should require a positive step from their client to authorise the requisite disclosure. This may include an appropriate 'opt-in' type approach.”
Accepting the invite is that positive step. Read what they accept in the end-user terms, clause 3.
What to tell a client, in our published words.
Paragraph 23 asks you to say where data will be stored and whether AI is used. These are the sentences our security page and subprocessor list carry. Quote them rather than summarising them.
Where it is stored
Your firm's own database and uploaded files are held on AWS in the region for the country you chose at sign-up: Australia (Sydney), New Zealand (Auckland), the United Kingdom (London), the United States (N. Virginia) or Canada (Montreal).
Firms outside Australia that signed up before their country's region opened in October 2026 are in Sydney and stay there unless they ask to move.
For every firm, the platform itself runs in Australia and reads your database from there, and your account records, logins, billing and usage records, EVA's conversation history and working notes, the analyses, reports, pulses and plans EVA writes for you, your saved report and dashboard definitions, in-app messages and operational logs are held in Sydney.
Where the AI runs
EVA runs on Amazon Bedrock under our AWS agreement. The model that orchestrates each request is supplied by Anthropic and runs in the AWS geography of your firm's region: Australia for firms hosted in Australia or New Zealand, Europe for firms hosted in the United Kingdom, the United States for firms hosted in the United States, and North America (Canada or the United States) for firms hosted in Canada. The model that does the heavy lifting is supplied by OpenAI and runs in that same geography for firms hosted in the United States or Canada, and for every other firm on AWS's global network, which may be outside your country. Neither model developer receives your data through Amazon Bedrock, and no model is trained on it. We also use the Anthropic API directly for web search, for document exports and as a backup, and that processing takes place in the United States.
Training: Never used to train any model, ours or anyone else's, whichever model sits underneath - committed in our Terms and Privacy Policy.
The detail behind both cards: security, subprocessors and the Data Processing Addendum.
Check it, then write down that you did.
Paragraph 16: verify at each step, be able to contest the output, document it. The review is yours. The platform keeps its own logs, and nothing it drafts acts without your approval.
Reviewing EVA’s work
- Check each number you will use against the ledger or report it came from.
- Ask the question a second way, or break it down, when an answer looks wrong. Contest it before you use it.
- Read every Dawn note, report and Pulse draft before it reaches a client, and decide what goes.
- Approve a Pulse's action only when you would have done the same thing yourself.
- Note on the client's file what you checked, and when.
EVA acts in a connected tool only after someone confirms. A Pulse acts only when you approve it, and only through the MCPs you have connected.
What you keep, and what the platform keeps
- what AI tool was used
- the purpose for which AI was used
- human review and verification undertaken throughout each step of the workflow
- the final advice or work product delivered
- client consent obtained, where relevant
“Records should be sufficient to demonstrate compliance with professional obligations, reasonable care, and the decision-making processes applied.”
Infrastructure and administrative actions logged (AWS CloudTrail), database connections audited, and EVA questions and answers traced. The date each invited client accepted the end-user terms is recorded against their membership.
A clause to start from.
Firms have always been able to ask us for a section for their engagement letter. This is that section, rewritten to what the platform does today, for a firm in Australia. The TPB’s own pointer is paragraphs 14 and 15 of TPB(GS) 34/2019.
We use VibeCFO, a reporting and AI platform provided by One Place Business Platform Pty Ltd (ACN 621 278 180), to analyse your financial information and to prepare reports and commentary for you. To do that, information relating to your affairs, including data from the accounting and other systems connected to your workspace, is disclosed to VibeCFO and processed on its platform.
Your business's database and uploaded files are held on Amazon Web Services in Sydney, Australia, and the VibeCFO platform runs in Australia. VibeCFO's AI assistant, EVA, uses models supplied by Anthropic and OpenAI, and some of that processing may take place outside Australia, including in the United States. VibeCFO publishes its current suppliers, and where each processes data, at vibecfo.ai/subprocessors, and states that no model is trained on your data.
AI output can contain errors. We review anything produced with AI before we rely on it or give it to you, and we remain responsible for the advice and services we provide to you.
When we invite you into your VibeCFO workspace, you will be asked to accept VibeCFO's end-user terms before you can sign in. By signing this letter, and by accepting those terms, you consent to the disclosure and processing described above.
You can withdraw this consent at any time by telling us in writing. We will then stop using VibeCFO for your work and ask VibeCFO to remove your data, which it removes from its production systems within the period stated in its Terms.
A starting point for your own letter, not legal advice. It reflects what VibeCFO publishes today: check it against our security and subprocessor pages when you use it, and have your adviser check it against your engagement, TPB(GS) 34/2019 and the Privacy Act.
Existing clients? The TPB’s answer: “If AI use represents a material change to service delivery or data handling practices, tax practitioners should consider updating their engagement terms and informing affected clients.”
Nine things, once.
Decide where EVA fits
Which clients, which work, and what a person checks before anything is relied on (para 9).
File your due diligence
Read the security page, the subprocessor list and the addendum, and keep them on file (para 25).
Update your engagement letter
Add the clause below. For existing clients, if this is a material change, update their terms and tell them (the TPB's Q&A).
Invite each client in
They accept the end-user terms before they get in: their own positive step (para 23, GS 31/2018).
Say where processing happens
Never tell a client that everything stays in Australia (GS 31/2018). Use the facts on this page.
Review before reliance
Every output, every time, and note the review (paras 16 and 17).
Keep the five records
The tool, the purpose, the review, the final work and the consent (the TPB's Q&A; Determination s 30).
Write it into your policies
Your quality management system, and training for everyone who uses EVA (Determination ss 35 and 40).
Take advice on TFNs
Whether the Privacy (Tax File Number) Rule 2015 applies to your use of AI (para 26).
The TPB endorses no AI provider, VibeCFO included
In the TPB’s words: “No, the TPB does not approve or endorse specific AI providers. Tax practitioners are responsible for assessing whether a particular AI tool is suitable for their circumstances.” This page shows how VibeCFO helps you meet TPB(GS) 55/2026. It is not legal advice, and it does not replace your own reading of the guidance.
TPB(GS) 55/2026 and EVA, answered.
Do I need client consent before putting client data into EVA under TPB(GS) 55/2026?
Yes. Paragraph 23 says you must obtain permission from each client before divulging their information to a third party, which can include entering it into AI tools, and recommends telling them to whom and where it goes, where it is stored and whether AI is used. With VibeCFO the client takes that step when they accept your invite, and your engagement letter should say the same.
Is VibeCFO a third party under Code item 6?
Yes. Paragraph 21 defines a third party as any entity other than the client and the tax practitioner, so VibeCFO is one, and so are the AI providers named on our subprocessor list.
Does any client data leave Australia when I use EVA?
Some processing can. EVA runs on Amazon Bedrock under our AWS agreement. The model that orchestrates each request is supplied by Anthropic and runs in the AWS geography of your firm's region: Australia for firms hosted in Australia or New Zealand, Europe for firms hosted in the United Kingdom, the United States for firms hosted in the United States, and North America (Canada or the United States) for firms hosted in Canada. The model that does the heavy lifting is supplied by OpenAI and runs in that same geography for firms hosted in the United States or Canada, and for every other firm on AWS's global network, which may be outside your country. Neither model developer receives your data through Amazon Bedrock, and no model is trained on it. We also use the Anthropic API directly for web search, for document exports and as a backup, and that processing takes place in the United States. So never tell a client that all the work is done in Australia: TPB(GS) 31/2018 asks you not to imply it when it is not the case.
Where is my client's database stored, and where does the AI run?
Your firm's own database and uploaded files are held on AWS in the region for the country you chose at sign-up: Australia (Sydney), New Zealand (Auckland), the United Kingdom (London), the United States (N. Virginia) or Canada (Montreal). For every firm, the platform itself runs in Australia and reads your database from there, and your account records, logins, billing and usage records, EVA's conversation history and working notes, the analyses, reports, pulses and plans EVA writes for you, your saved report and dashboard definitions, in-app messages and operational logs are held in Sydney. The AI's locations are in the answer above and on our security page.
What should my engagement letter say about AI?
The TPB points to paragraphs 14 and 15 of TPB(GS) 34/2019, its guidance on letters of engagement. This page gives you a clause to start from: who provides the platform, where data is held and processed, that you review AI output and stay responsible, how the client consents and how they withdraw. Have your adviser check it before you use it.
Do existing clients need new engagement letters before I invite them?
The TPB's answer: "If AI use represents a material change to service delivery or data handling practices, tax practitioners should consider updating their engagement terms and informing affected clients." Inviting a client into VibeCFO for the first time usually is that kind of change.
What records do I need to keep when I use AI on a client file?
The TPB suggests records that show what AI tool was used; the purpose for which AI was used; human review and verification undertaken throughout each step of the workflow; the final advice or work product delivered; and client consent obtained, where relevant. On the platform side: Infrastructure and administrative actions logged (AWS CloudTrail), database connections audited, and EVA questions and answers traced.
Can I send a Dawn note or an EVA report straight to a client?
Not without reading it. Paragraph 8 says AI output is assessed and supplemented by professional judgement before it is relied on, and paragraph 16 says to verify it at each step and document that. Read it, check the numbers you will use, and then send what you stand behind.
Who is responsible if EVA gets a number wrong?
You are responsible for the services you provide (paragraph 8), and VibeCFO's terms say EVA's output can contain errors and must be reviewed. The numbers EVA returns come from the client's own database, so the check is against the ledger it came from.
Can EVA post journals, lodge or email clients by itself?
No. EVA acts in a connected tool only after someone confirms, and a Pulse acts only when you approve it, and only through the MCPs you have connected.
Does VibeCFO have ISO 27001 certification?
Not yet. ISO/IEC 27001:2022 and ISO/IEC 42001 certification is in progress, not yet certified. Gap analysis complete, management review held, remediation under way with an independent internal audit and external audit scheduled. Target certification: December 2026.
Should TFNs go into EVA?
Paragraph 26 says the Privacy (Tax File Number) Rule 2015 adds obligations where client information involves TFNs, and to take your own advice on whether it applies to you. Until you have that advice, keep TFNs out of the questions you ask EVA and the documents you give it.
Does training on EVA count towards my CPE?
The TPB says: "AI-related training can count towards CPE where it is relevant to maintaining or improving a tax practitioner's professional knowledge and skills." Whether a given session counts is for you to judge against that test and your association's rules.
Does the TPB approve VibeCFO?
No, and it approves no one. In the TPB's words: "No, the TPB does not approve or endorse specific AI providers. Tax practitioners are responsible for assessing whether a particular AI tool is suitable for their circumstances." This page shows how VibeCFO helps you meet the guidance. It is not an endorsement and not legal advice.
Does the guidance cover management reporting, or only tax returns?
TPB(GS) 55/2026 is written for tax agent services, and BAS services are among them. Some of what a firm does in VibeCFO is advice rather than a tax agent service, but it is the same client's data, and Code item 6 is about information relating to a client's affairs. Most firms will find it simpler to apply the same permission and review to all of it. Ask your adviser where the line falls for you.
Bring two clients through the invite.
Invite your simplest client and your most careful one. If the invite, the terms and the review do not fit how your practice works, you will know inside the trial. Questions about this page? Talk to us first.