What AICPA, State Boards, and the FTC Actually Require for Your Accounting Firm's Digital Marketing

Accounting firm digital marketing operates under three overlapping regulatory frameworks. Understanding where each applies—and where they conflict—prevents the compliance gaps that trigger board complaints or FTC scrutiny.

Disclaimer: This is educational content about regulatory frameworks, not legal or professional compliance advice. Rules change, and state-specific variations apply. Verify current requirements with your state board of accountancy and legal counsel before implementing marketing strategies.

Layer 1: AICPA Code of Professional Conduct

ET Section 1.600 (Advertising and Other Forms of Solicitation) establishes the baseline. The core prohibition: advertising that is false, misleading, or deceptive. This includes claims that create unjustified expectations of favorable results, imply the ability to influence official bodies, or contain misrepresentations about fees, services, or qualifications.

Layer 2: State Board of Accountancy Rules

Your state board adds specific restrictions on top of AICPA guidelines. These vary significantly—some states prohibit comparative advertising entirely, others regulate testimonial usage, and many have specific rules about credential display and firm name conventions. You're bound by the rules of every state where you hold a license or solicit clients.

Layer 3: FTC Endorsement Guidelines

The Federal Trade Commission's endorsement guidelines apply to all businesses using testimonials, reviews, or influencer relationships. For accounting firms, this primarily affects how you collect, display, and attribute client reviews and case study results.

The AICPA's advertising rule translates directly to your website content, Google Business Profile, and any digital marketing. Here's what the prohibition on "false, misleading, or deceptive" means for common SEO practices:

Service Page Claims

Statements like "we guarantee tax savings" or "our clients always get refunds" create unjustified expectations. Compliant alternatives focus on process and qualifications: "Our tax planning approach analyzes [specific strategies]" or "Licensed CPAs with [X] years specializing in [industry]."

Results and Case Studies

You can discuss client outcomes, but context matters. "We saved Client X $50,000" without noting the specific circumstances or that results vary could be considered misleading. Compliant case studies include qualifying language: "Results depend on individual circumstances. This example involved [specific situation]."

Credential and Specialty Claims

Implying specializations you don't hold, or using credential designations incorrectly, violates ET Section 1.600. If your firm doesn't hold a specific certification (ABV, CFF, CGMA), don't optimize for keywords that imply you do. Accurate representation extends to staff credentials—claiming "our team of CPAs" when only one partner holds the license is potentially misleading.

Comparative Statements

Claims about competitors ("unlike other firms, we actually return calls") require careful handling. AICPA guidelines don't prohibit comparative advertising outright, but unsubstantiated superiority claims that disparage competitors may cross the line into misleading territory—and some state boards prohibit comparative claims entirely.

State board rules create the most compliance complexity because they vary significantly and you must comply with rules in every jurisdiction where you're licensed or soliciting clients. As of 2024, here are the major categories of variation:

Testimonial Restrictions

Some states (historically Texas and a few others) have restricted or required specific disclaimers for testimonials. Many states have modernized these rules, but restrictions remain in some jurisdictions. Check your state board's current advertising rules before implementing review generation campaigns.

Comparative Advertising

Several state boards prohibit or restrict comparative claims about other CPA firms. This affects content that positions your firm against competitors, even implicitly. Statements like "more responsive than the typical accounting firm" may trigger scrutiny in restrictive states.

Credential Display Rules

State boards regulate how you display CPA credentials, firm names, and license numbers. Common requirements include displaying license numbers on marketing materials, restrictions on firm names that imply scope beyond accounting services, and rules about which individuals can be listed as principals.

Fee Advertising

Rules about advertising fees vary—some states require specific disclosures, others prohibit certain fee representations. If your SEO strategy includes pricing pages or fee transparency content, verify your state's specific rules.

Practical step: Download your state board's rules of professional conduct and search for sections on "advertising," "solicitation," and "communications." When in doubt, contact your state board directly—they typically provide guidance on advertising compliance questions.

The FTC's endorsement guidelines affect how accounting firms collect and display reviews, use client testimonials, and handle any material connections in marketing content.

Material Connection Disclosure

If there's any connection between your firm and the person providing an endorsement that might affect credibility, it must be disclosed. This includes:

• Employees or their family members providing reviews
• Clients who received discounted or complimentary services in exchange for testimonials
• Referral partners or professional connections
• Case studies from clients with ongoing business relationships

Review Generation Compliance

You can ask clients for reviews—the FTC doesn't prohibit solicitation. However, you cannot selectively solicit only clients likely to leave positive reviews ("review gating"), incentivize positive reviews specifically (offering discounts for 5-star reviews), or suppress negative reviews while promoting positive ones.

Testimonial Representation

Testimonials must reflect the honest opinions of real clients, and you can't edit testimonials to change their meaning. If a testimonial mentions specific results, those results must be typical or you need clear disclosure that results vary.

Online Endorsement Disclosures

Disclosures must be clear and conspicuous—not buried in fine print or hidden behind "read more" links. For video testimonials, verbal disclosure is typically required. For written testimonials on your website, disclosure should appear near the testimonial itself, not just in a site-wide terms page.

The intersection of FTC guidelines and state board rules creates the compliance framework for your review management strategy. Our testimonial and review compliance guide covers this in detail.

Based on patterns we've observed in the accounting vertical, these SEO practices most commonly create compliance risk:

Risk: Overpromising Results in Title Tags and Meta Descriptions

Aggressive title tags like "designed to Tax Savings | [Firm Name]" or meta descriptions promising specific outcomes violate ET Section 1.600's prohibition on claims creating unjustified expectations. These appear in search results and establish promises before prospects reach your disclaimer pages.

Compliant alternative: Focus on process and qualifications rather than designed to outcomes. "Tax Planning for Small Business | Licensed CPAs Since [Year]" makes no result promises.

Risk: Implied Credentials Through Keyword Optimization

Optimizing for keywords like "forensic accountant [city]" when you don't hold CFF certification misrepresents qualifications. Search engines treat your optimization targets as claims about your services.

Compliant alternative: Optimize for services you actually provide and credentials you actually hold. If you offer litigation support without CFF certification, "litigation support accounting" is more accurate than "forensic accounting."

Risk: Client Logo Walls Without Disclosure

Displaying client logos implies endorsement. If those clients haven't explicitly agreed to endorsement use (not just a privacy policy), this may violate FTC guidelines. Some state boards also have rules about client identification.

Risk: Review Response Confidentiality

Responding to negative reviews sometimes tempts firms to discuss engagement details. Even confirming someone was a client may violate confidentiality obligations under ET Section 1.700, depending on circumstances.

The reputation management guide covers compliant review response strategies.

Compliance isn't a one-time audit—it's a process integrated into how you create and approve marketing content. Here's a practical framework:

Content Review Checklist

Before publishing any page, review for:

• Result claims: Does this promise or imply specific outcomes? Add qualifying language or remove.
• Credential accuracy: Are all certifications, licenses, and specializations accurately represented?
• Testimonial compliance: Are disclosures present and conspicuous?
• Comparative statements: Do we claim superiority over competitors? Is this substantiated and compliant with state rules?
• Fee representations: If discussing pricing, does this comply with state board fee advertising rules?

Multi-State Compliance Process

If you're licensed in multiple states or serve clients across state lines, your marketing must comply with the most restrictive applicable rules. Practical approach: identify the most restrictive state among your licenses and use those standards as your baseline.

Ongoing Monitoring

Rules change. State boards update advertising guidelines. FTC enforcement priorities shift. Establish a quarterly check-in to verify current requirements haven't changed for your jurisdiction.

When you work with an SEO provider, they should understand these compliance requirements. Our SEO services for accounting firms are built around AICPA and state board rules—because rankings that trigger board complaints aren't worth having.

Final note: This framework provides educational orientation, not comprehensive compliance guidance. Work with your firm's legal counsel and verify current rules with your state board before implementing marketing strategies.