EU AI Act for accountants: what already applies and what can you do for clients?
An honest explanation for accountants and bookkeeping firms: which AI Act obligations apply to your own practice, and why clients will soon turn to you with AI compliance questions.
- AI literacy (Article 4 of the EU AI Act) already applies to every accounting firm using AI tools: from Copilot in Office to AI features in accounting software. This has applied since 2 February 2025.
- Your accounting firm is a deployer. The fact that your accounting software is itself compliant does not make your firm compliant as a deployer. Those are two separate responsibilities.
- Clients will soon ask you: 'Are we compliant with the AI Act?' As their trusted adviser, you will want to be able to answer.
- Delahaye Solutions’ AI Act Scan makes your practice compliant in about a week for a fixed price of €750 (small teams) or €1,500 (10-50 employees). White-label for clients available.
Accountants are heavy AI users, and that comes with obligations
Modern accounting software increasingly includes AI features: automatic processing of receipts and invoices, AI classification of transactions, and smart suggestions for booking rules. On top of that, many accountants use Microsoft Copilot for correspondence, reports, and summaries. All those tools fall under the EU AI Act, and your firm is the deployer. That means responsibility for how those AI tools are used properly rests with your firm, even when they were built by your software supplier. The AI literacy obligation (Article 4) already applies.
Three things every accountant needs to know
The EU AI Act distinguishes between who builds AI (the provider) and who uses AI (the deployer). For accounting practices, the latter category is most relevant.
You are a 'deployer', even for AI you buy in
If you use AI tools in your practice, even if you purchase them from a supplier, you are a deployer under the EU AI Act. That applies to AI features in your accounting package, Copilot in your Office suite, AI-driven document processing, and any custom automations. The Act divides responsibility: the supplier is responsible for how the AI is built; your firm is responsible for how employees use it.
Article 4 requires documented role-based training
Article 4 of the EU AI Act requires you to ensure that employees using AI tools have adequate 'AI literacy': they need to understand how the tools they use work, what their limitations are, and what risks come with them. The Act does not prescribe exactly what form this takes, but it must be documented and matched to each employee's role. For an accountant who uses AI when processing receipts: does that employee know when to check the output? Is that documented? If the answer to both is yes, you are well on your way.
Your clients fall under it too, and they will ask you
Every SME using AI tools, including your clients, falls under Article 4. And who is the first port of call for compliance questions for SMEs? Their accountant. That means you will soon receive questions like: 'We use ChatGPT for our customer service, are we compliant?' or 'Our HR software has AI features, what do I need to do?' If your practice is compliant, you can answer. If you want to handle it for clients too, we can work on that together.
How your accounting practice becomes compliant with Article 4
Compliance with the AI literacy obligation does not require a large project. Three steps: (1) Carry out an AI inventory. Map which AI tools employees in your practice use: Copilot, AI features in your accounting software, AI-driven document processing, any chatbots or automations. (2) Record this in an AI register. Per tool: who uses it, for what, which decisions does it support, and who is responsible? One clear document is enough. (3) Provide AI literacy training per role. Not a generic e-learning, but tailored to what accountants and administrators encounter day to day. Document that you did this. These three steps form the core of what Article 4 requires.
Frequently asked questions about the EU AI Act for accountants
Do AI features in my accounting software fall under the Act?
When do the obligations take effect for accountants?
Do I have to proactively advise clients about the AI Act?
How quickly can I make my practice compliant?
Can we offer the AI Act Scan to clients too?
Make your practice compliant?
Book a free intake for the AI Act Scan. We look together at the AI tools in your practice, what your employees know, and what is needed. Free and without commitment.
Book a free AI Act intake →Free and without obligation · Reply within one business day · Fixed price up front, no surprises