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AICPA releases revised independence interpretation "Information System Services"

An Official Release announced the Professional Ethics Executive Committee's (PEEC's)  revised interpretation “Information System Services,” formerly “Information Systems Design, Implementation, or Integration” (ET sec. 1.295.145) under the “Independence Rule” (ET sec. 1.200.001), which the PEEC adopted at its May 2019 meeting.  

The revised interpretation addresses the following nonattest services involving an attest client's information system or network: 

  • Design and development
  • Implementation, which includes: installation, customization, integration, interfacing, configuration and data translation
  • System and network maintenance, support and monitoring

The revision incorporates several defined terms, most notably "financial information system," which is key to avoiding self-review threats that impair independence. However, the interpretation also applies to attest services where the subject matter is not the financial statements.

Overall, the revised interpretation provides more explicit guidance on information system services, especially the types of implementation and system and network maintenance services that impair independence.

The revised interpretation is effective January 1, 2021 and early implementation is allowed. The revised interpretation will be added to the AICPA Code of Professional Conduct with the June 2019 update.