AICPA to seek inputs on updated guidelines for alternative practice structures 

The American Institute of CPAs’ (AICPA) Professional Ethics Executive Committee (PEEC) has voted to seek public comment on the proposed changes to the AICPA Code of Professional Conduct that will have a bearing on the alternative practice structures (APS), especially those involving private equity investment.  

The draft, titled “Proposed Revisions Related to Alternative Practice Structures,” will be posted online by 29 December 2025.  

Comments to the draft can be given until 30 April 2026.  

Feedback from an earlier discussion memo circulated by the PEEC task force has been considered in preparing this new version. 

Although the Code has included guidance on APS for many years, recent growth in private equity’s presence in accounting prompted a review of current rules.  

The new draft outlines “relationships and circumstances” that could “impair” independence. It also details criteria for assessing such risks. 

“These changes aim to uphold the integrity of the profession while offering practical guidance for firms operating in alternative practice structures,” stated the exposure draft. 

One of the main areas for comment is a revised interpretation of independence as it applies to APS.  

This covers attest firms closely linked to nonattest entities that are at least partially owned by investors.  

The proposed revisions would distinguish between “significant influence” and “control” by investors over nonattest entities. It also provides guidance on how these terms impact independence evaluations. 

Other proposed updates include on the interpretation of “Alternative Practice Structures” under the “Form of Organisation and Name Rule.”  

There are also revisions to the “Conceptual Framework for Independence”, an important guidance for navigating complex APS scenarios. 

Revisions include for the “Conceptual Framework for Members in Public Practice” interpretation and to the definition of “network firm”, a term in the Code that refers to entities required to meet independence standards when performing audits or reviewing clients.  

If adopted next year, these updates would come into effect one year after their approval. Firms could also implement these revisions earlier too. 

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