What AICPA, State Boards, and the FTC Actually Require From Your Website — and What They Don't

The AICPA Code of Professional Conduct, Section ET §1.600, establishes the foundational advertising standard for CPAs who are AICPA members. The rule prohibits communications that are false, misleading, or deceptive. That standard sounds straightforward until you apply it to the specific content decisions that SEO requires.

Here is where the rule becomes relevant to your website and organic search strategy:

• Page titles and meta descriptions are public-facing claims. Titles like "#1 CPA Firm in Dallas" or "Best Tax Accountant" are the kind of superlative statements that regulators view as inherently unverifiable and potentially misleading.
• Blog content and case studies that imply designed to outcomes — "We saved our clients thousands" — can trigger scrutiny if they omit material context about the client's specific situation.
• Service descriptions that overstate scope, such as claiming audit capability the firm does not hold, are a clear violation.
• Results-oriented SEO copy that promises specific financial outcomes for prospective clients is generally high-risk under this standard.

ET §1.600 applies to AICPA members specifically. However, most state boards have adopted identical or nearly identical language in their own rules, meaning the practical effect is the same whether or not a CPA maintains AICPA membership.

The safe operating principle: any claim on your website that a regulator could not independently verify — or that a reasonable person could find misleading without additional context — warrants either revision or a qualifying disclaimer.

This is educational content, not legal or accounting advice. Consult your state licensing authority or qualified counsel for guidance specific to your situation.

AICPA standards set a floor. State boards set the actual enforceable rules for licensed CPAs practicing in their jurisdiction — and those rules differ meaningfully from state to state. For SEO purposes, the three areas that generate the most compliance questions are: testimonials, specialization claims, and fee advertising.

Testimonials

Some state boards historically prohibited client testimonials in CPA advertising entirely. That landscape has shifted in many jurisdictions, but not universally. Texas, for example, under State Board Rule §501.90, permits testimonials provided they do not contain false or misleading statements and include a disclaimer that the results are not necessarily representative of all clients' experiences. Other states may require similar disclaimers, while a smaller number maintain stricter limits. Do not assume your state follows the same rules as a neighboring state.

Specialization and Expert Claims

Describing yourself as a "specialist" or "expert" in a particular area — estate tax, forensic accounting, international tax — is regulated in most states. Typically, a CPA may use such language only if a recognized credentialing body has granted that designation. General language such as "extensive experience in" or "focused practice in" typically carries lower risk, but verify this with your state board's specific wording.

Fee Advertising

If your website lists service fees — even as ranges — state rules may require that the advertised fee be honored for the described service for a defined period. Publishing a fee range as a general reference without meeting this requirement can create regulatory exposure.

The practical implication for SEO: your content team, copywriter, or SEO agency needs a compliance checkpoint before publishing pages that include client results, credential claims, or pricing information. A one-time legal review of your content template is a reasonable investment.

State board rules change. Verify current requirements directly with your state's board of accountancy before making content decisions based on this guide.

The Federal Trade Commission's Endorsement Guides (16 C.F.R. Part 255, updated most recently in 2023) apply to any business collecting or publishing consumer endorsements — including accounting firms managing Google reviews or publishing client testimonials on their website.

The core requirement is clear and conspicuous disclosure of any material connection between the firm and the person providing the endorsement. For most accounting firms, the practical implications are:

• Incentivized reviews: If your firm offers any benefit — a discount, gift card, referral credit, or even entry into a drawing — in exchange for a Google review or website testimonial, that connection must be disclosed. Failing to disclose it violates FTC guidance regardless of whether the review itself is truthful.
• Referring clients who leave reviews: If a client who receives a referral fee or reciprocal business arrangement also leaves a public review, that relationship is a material connection requiring disclosure.
• Atypical results: The FTC requires that testimonials featuring outcomes not typical for most clients include a clear statement of what typical results look like. For accounting firms, this often means adding language such as "Results vary based on individual tax situation and applicable law."
• Fabricated or composite testimonials: The FTC prohibits reviews that are invented, aggregated from multiple clients, or attributed to fictional individuals. This includes AI-generated testimonial copy presented as real client statements.

For SEO, this matters because Google reviews directly influence local search rankings and Map Pack visibility. An aggressive review-generation program that involves incentives — without disclosure — creates FTC exposure even if it produces ranking results in the short term.

The reputation management page in this cluster covers ethical review generation in detail. For the compliance framing here: when in doubt, disclose, and do not incentivize.

Compliance risk in SEO for accounting firms tends to concentrate in a handful of specific content patterns. The following are the scenarios that most frequently require revision in our experience working with accounting firms.

Scenario 1: Superlative Meta Titles

Risk version: "Best CPA Firm in Phoenix | [Firm Name]"
Lower-risk version: "Phoenix CPA Firm | Tax, Audit & Advisory | [Firm Name]"
Superlative claims are unverifiable and specifically flagged under false advertising standards. They also add no keyword value that a factual title cannot achieve.

Scenario 2: Results-Forward Case Study Language

Risk version: "We saved this client $47,000 in taxes."
Lower-risk version: "Through a cost segregation analysis, this client identified significant deductions they had previously missed. Individual results depend on specific circumstances."
Specific dollar outcomes without context imply designed to results. Reframing around process and adding a results-vary disclaimer addresses the compliance issue without losing the persuasive value.

Scenario 3: Specialty Claims Without Credentials

Risk version: "Expert international tax specialists"
Lower-risk version: "CPA team with focused experience in international tax matters for U.S. expats and foreign-owned businesses"
"Specialist" and "expert" carry regulatory weight. Describing focus areas and client types communicates the same positioning without triggering credentialing requirements.

Scenario 4: Schema Markup Misrepresentation

Structured data — LocalBusiness schema, FAQ schema, review schema — must accurately reflect real information. Marking up fabricated reviews, inflating aggregate ratings, or listing service categories the firm does not offer creates both FTC and Google quality guideline exposure. Structured data that Google discovers to be misleading can result in manual actions against the site.

Scenario 5: Unlicensed Practice Scope

If a firm's website content describes legal services, investment advice, or other regulated activities that require separate licensure, that content creates liability independent of CPA advertising rules. Keep service descriptions within the firm's licensed scope.

Compliance and SEO are not in opposition. A website that makes accurate, specific, well-contextualized claims about a firm's experience and focus areas will rank — often more durably than one built on superlatives and vague guarantees. The practical challenge is building a review process that does not slow content production to a halt.

A workable approach for most firms:

1. Establish a one-time content policy document with your firm's legal or compliance advisor. This document defines what claim types require review, what disclaimer language is pre-approved, and which content patterns are off-limits. It becomes the reference guide for your marketing team or SEO agency.
2. Template your disclaimers. For testimonials, results statements, and specialization language, pre-draft the disclosure language once and apply it consistently. This removes the per-page decision burden.
3. Audit existing content annually. State board rules and FTC guidance change. A content audit once per year — checking existing pages against current standards — catches drift before it becomes a formal complaint.
4. Brief your SEO agency. Any agency writing content for a CPA firm should receive your content policy document and understand that accounting advertising is regulated. An agency unfamiliar with these constraints will not ask permission before publishing high-risk copy.

If your firm is working with an SEO partner, ask directly: how do they handle compliance review for regulated industries? Agencies with experience in financial services verticals will have a process. Those without experience may not understand that the question matters.

For firms evaluating SEO support with these constraints in mind, our compliant SEO services for accounting firms are built around content standards that meet AICPA and state board requirements — while still producing content that ranks and converts.