{
  "question_id": "CG-MCE-143",
  "slug": "how-a-bookkeeping-or-accounting-firm-offboards-a-client-it-is-disengaging",
  "display_title": "How should a bookkeeping or accounting firm offboard a client it is disengaging — what must be handed over, what does the firm keep, and how is access ended?",
  "format": "article-v2",
  "applies_to": {
    "countries": [
      "US"
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    "frameworks": [],
    "tax_year": null,
    "platforms": []
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  "general_concept": false,
  "summary": "Put the effective date, finished and unfinished work, and each later deadline's owner in a dated letter. Sort your files by category, return what your rules require in a usable form, and check those rules before withholding anything over unpaid fees. Extract and deliver before revoking access, then end access both ways on every system. Answer a successor only with the client's authority, keep confidences except where law requires or permits disclosure, and log each step.",
  "body": "## Which rules bind your firm?\n\nWhat you must return, may withhold and may disclose depends on your status. Settle it first, and comply with every set that applies:\n\n- **IRS practitioners.** Circular 230's §10.2 defines a practitioner as an individual described in §10.3(a) to (f): attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents and registered tax return preparers, each while not under suspension or disbarment from practice before the IRS. The duties used below (§10.20, §10.21 and §10.28) sit in its Subpart B, whose obligations the IRS's Annual Filing Season Program page says participants consent to adhere to.\n- **AICPA members.** The AICPA Code of Professional Conduct's Records Requests interpretation and Confidential Client Information Rule apply, and the Code says members must also comply with the rules of authoritative regulatory bodies such as state boards of accountancy, including a board's more restrictive rules on returning records.\n- **State licensees.** Board rules differ by state. California's appear below only as an example; read your own board's rules.\n- **Tax return preparers.** For §7216's disclosure rules, the IRS's Section 7216 FAQ counts as a tax return preparer anyone who assists others in preparing returns or performs auxiliary services in connection with preparing them. The IRS marks that FAQ as historical, warns it may not reflect current law and should not be relied on alone; confirm the definitions, consent rules and exceptions in Treas. Reg. §301.7216 and Revenue Procedures 2013-14 and 2013-19 before disclosing tax return information. The retention rule in 26 U.S.C. 6107(b) binds a person who is a tax return preparer with respect to a return or claim for refund.\n- **Unlicensed bookkeeping-only businesses.** Circular 230, the AICPA Code and board rules are written for practitioners, members and licensees. If your work assists in preparing returns or performs auxiliary services for it, the FAQ's definition reaches you. Either way, check your engagement agreement and your state's law before releasing or withholding anything.\n\n## How do you fix the end date and scope in writing?\n\nWhoever ended the relationship, send the client a dated letter or email that states:\n\n- The effective date after which the firm does no further work\n- The work completed to that date, by period and deliverable\n- The work in progress, its state, and whether you will finish it or hand it over\n- The work you will not do, including anything the client may assume is covered\n- Each filing, deposit or payment due after the effective date, and who owns it\n- What you will return, how and when, and what you will keep\n- The access you will remove and any role or subscription the client must take over\n\nIf the client is leaving, confirm the date and ask who should receive the handover. If you are resigning, say which work in progress you will finish first. If the relationship has lapsed, send the letter anyway: until it goes out, neither side can show who owns the next deadline.\n\nWhatever the path, if you are a Circular 230 practitioner retained by the client on a matter administered by the IRS and you know the client has not complied with the U.S. revenue laws, or has made an error in or omission from a return or other paper it submitted or executed under them, §10.21 requires you to advise the client promptly of that fact and of its consequences under the Code and regulations. Send that advice in its own letter.\n\nGive every later deadline a named owner, because each side can assume the other has it. If you run the client's payroll, name the last run and deposit you will process and who handles the next.\n\n## Which items are the client's records and which are your working papers?\n\nThe category decides what goes back. The AICPA Code's Records Requests interpretation sorts a file into four groups:\n\n| Category | What the Code says it covers | Does it go back? |\n|---|---|---|\n| Client-provided records | Accounting or other records belonging to the client that were provided to you by, or on behalf of, the client | Yes, when first requested |\n| Member-prepared records | Records you were not specifically engaged to prepare that are not in the client's books and records or otherwise available to it, leaving its financial information incomplete, such as adjusting, closing, combining or consolidating journal entries you proposed or prepared in an engagement such as an audit | Yes, if they relate to a completed and issued work product, unless fees are due for that specific work product |\n| Work products | Deliverables set out in the terms of the engagement, such as tax returns | Yes, unless fees are due for that product, it is incomplete, withholding is needed to comply with professional standards, or litigation concerning the engagement or your work is threatened or outstanding |\n| Working papers | All other items prepared solely for the engagement, such as your analytical review schedules and items the client prepared at your request reflecting your testing | No: the Code calls them your property, though statutes, regulations and contracts may impose more |\n\nA report your firm produced is not client-provided: that row turns on who supplied the record. The Code lets you and the client agree other terms for member-prepared records and work products, so check your engagement letter, including whether it names your ledger work as a deliverable.\n\nTwo other rules move items between rows:\n\n- **Circular 230.** §10.28 counts as records of the client documents or materials given to or obtained by you in the representation that preexisted your retention; materials the client or a third party (not your employee or agent) prepared and gave you about the matter; and a return or other document you presented to the client in a prior representation if the client needs it for current federal tax obligations. It excludes a document you prepared while you withhold it pending payment of fees the client contractually owes for that document.\n- **California.** The Board of Accountancy's regulation §68 says that where working papers include records ordinarily part of the client's books and records and not otherwise available to the client, the information on them must be treated as part of the client's books and records.\n\n## What must you hand over, and how?\n\nThe AICPA Code defines making records available as providing them in any format that is usable and accessible, regardless of the format in which they were received, and says a member required to return records should comply as soon as practicable and, absent extenuating circumstances, no later than 45 days after the request. For repeat copies, member-prepared records and work products, the Code says a request for a specific format you hold should be honored, records not in electronic form need not be converted, and formulas need not be provided unless you were engaged to provide them in a completed work product or they produced member-prepared records without which the client's financial information would be incomplete.\n\nBuild the handover from every category your rules release:\n\n- An index listing each item, its period, its format and where it sits\n- The client-provided records\n- Member-prepared records and work products due for release, such as adjusting entries not in the client's books that relate to completed work, and completed returns\n- Any prior-engagement document the client needs for current federal tax obligations and, for California licensees, working-paper information treated as the client's books\n- The ledger, left in the client's own platform where the client owns it, with the exports a successor needs\n- A list of open items: unreconciled accounts, unfiled returns, notices received and pending deadlines\n\nIntuit's help page \"Export your QuickBooks Online data\" (updated August 3, 2026) says its reports-and-lists export saves info from posting transactions that affect account balances, and gives separate steps for non-posting transactions such as estimates and purchase orders and for customer statements, attachments, recurring templates, the chart of accounts, and products and services; export each one a QuickBooks Online client uses.\n\nDeliver to the client, or to a person the client names in writing, by a method that records delivery, and ask for receipt to be confirmed against the index; if it is not, keep your delivery evidence. A handover to anyone but the client is a disclosure: get the consent described in the successor section below first.\n\n## Can you hold records back while fees are unpaid?\n\nOnly as far as the rules binding you allow. Send the final invoice for work to the effective date, and decide what to release by category, not by balance owed.\n\nCircular 230's §10.28 says a practitioner must, at the client's request, promptly return any and all records of the client necessary for the client to comply with federal tax obligations, and that a dispute over fees generally does not relieve the practitioner of that duty. If applicable state law allows or permits retention of a client's records in a dispute over fees for services rendered, the practitioner need only return the records that must be attached to the taxpayer's return, but must give the client reasonable access to review and copy the additional records retained under state law that the client needs for federal tax obligations.\n\nThe AICPA Code says client-provided records may not be withheld for nonpayment of the reasonable fee a member may charge to retrieve, copy and ship them; for member-prepared records, work products and repeat copies, a member may charge that fee and require payment first. It says a state statute granting a lien on records does not relieve a member of these obligations, and that not complying with the interpretation violates its Acts Discreditable Rule.\n\nCalifornia's regulation §68 says a licensee shall not retain the client's records after demand by or on behalf of the client, and that unpaid fees do not constitute justification for retention of client records.\n\n| If fees are | Then |\n|---|---|\n| Settled | Return what your rules require after the request: promptly under Circular 230 and, for AICPA members, as soon as practicable and, absent extenuating circumstances, within 45 days; put that date in your letter |\n| Unpaid and undisputed | Pursue the debt separately, withhold only what your rules permit for that specific work, and return the rest promptly |\n| Unpaid and disputed | Do the same; under Circular 230, confirm your state's law permits retention before relying on the narrower duty, and give the client reasonable access to the rest. Relying on it does not lift a stricter rule that also binds you: the AICPA Code says a lien that state statutes grant does not relieve a member of its records duties, and California's §68 says unpaid fees do not justify retaining client records |\n\nIf the relationship is ending badly, keep every letter factual, answer the records request separately from any demand for payment, and never make delivery conditional on payment unless a rule binding you permits it.\n\n## What does the firm keep, and does a retention duty attach?\n\nKeep copies of what you return, and your own working papers. Circular 230's §10.28 lets a practitioner retain copies of records returned to a client, and the AICPA Code lets a member make and retain copies of records already made available.\n\nA retention duty attaches to what you keep where a rule binding you imposes one. 26 U.S.C. 6107(b) requires a person who is a tax return preparer with respect to a return or claim for refund to retain a completed copy of it, or a list of the taxpayer's name and identification number, and to make the copy or list available for inspection on request by the Secretary. California's regulation §68.1 requires licensees to retain working papers. If neither binds you, check your state's law and your engagement agreement. How long each item must be kept, including any hold while an investigation or legal action is pending, is a separate question.\n\n## In what order do you end access, and on which systems?\n\nExtract first and revoke last, in this order:\n\n1. **Map ownership.** List every system you touched: the accounting platform, bank and card portals, payroll, federal, state and local tax agency accounts, document stores and shared folders, connected apps, bank feeds, email forwarding rules and mail sent to your address. Record who holds each subscription and each master or primary admin role. Note every account where you use a login the client shared, or where a firm phone, email or authenticator is a second factor or recovery contact.\n2. **Extract and deliver.** Export and deliver everything the client is entitled to while you still have access, and get receipt confirmed. Intuit's help page \"What happens to my QuickBooks Online data after I cancel?\" (updated August 5, 2026) recommends exporting or printing data before cancelling; it says a subscriber who cancels keeps read-only access for one year, but an account whose card is declined has 14 days to update billing, is then suspended, and must be re-subscribed to reach the data. Neither statement says what ending your firm's billing does to a client's company.\n3. **Transfer roles and subscriptions.** Make the client the holder of any master role or subscription you hold for them, and confirm they can sign in, before removing yourself.\n4. **Remove your access.** Delete your firm's users from the client's ledger, bank, card and payroll portals and from any document store or shared folder the client owns; withdraw any login or authorization you hold for the client with a state or local tax agency, following that agency's instructions; disconnect apps, feeds and connections set up under your credentials; and end your authority to approve or release the client's payments or payroll. Have the client's administrator confirm the user and sharing lists after your removal.\n\n   For each account noted in step 1, have the client change the password and remove your second factors and recovery contacts; delete every stored copy of the credentials, and record the client's confirmation. If you act for the client's employment taxes under a Form 8655 reporting agent authorization or Form 2678 agent appointment, end it following the IRS's instructions for that form and name in your letter the last return and deposit filed under it and who files the next.\n\n5. **Withdraw your IRS power of attorney.** The IRS's Form 2848 instructions have a representative write \"WITHDRAW\" across the top of the first page, add a current signature and date below it, and send a copy to the IRS as a revocation is sent: by mail or fax using the Where To File Chart or, for a specific matter, to the IRS office handling it. Without a copy, the representative sends the IRS a signed, dated statement of withdrawal listing the matters and years or periods and the taxpayer's name, taxpayer identification number and address (if known).\n6. **Have the client revoke your tax information authorizations.** The IRS's Form 8821 instructions have a taxpayer revoke one, without submitting a new authorization, by writing \"REVOKE\" across its top with a current signature and date under the original signature. Without a copy of one that is not specific-use, the taxpayer sends the IRS a signed, dated notification at the Where To File Chart address that the designee's authority is revoked, listing each designee's name and address and the tax matters and periods; a specific-use authorization or notice of its revocation goes to the IRS office handling the case.\n\n   The Form 8821 instructions do not say where an annotated copy that is not specific-use goes. A practical route, not one the IRS names, is for the client to mail or fax it to the Where To File Chart address or fax number, with the current signature handwritten as the instructions require for a Form 8821 sent by mail or fax, then keep the transmission record and copy you. If the client does not act, note that in the offboarding record.\n\n7. **Close mail and forwarding.** If IRS mail for the client comes to you, the client changes its last known address with the IRS on Form 8822 for a home address or Form 8822-B for a business address, the forms the IRS's Form 2848 instructions name, and removes any email forwarding rule that sends its mail to you.\n8. **End the client's access to your systems.** Once receipt is confirmed or your delivery evidence is complete, disable the client's portal login and expire shared links, keeping the files you must retain.\n9. **Log each step.** Enter it in the offboarding record as you finish it.\n\nWho owns the subscription and admin role changes step 3:\n\n| If | Then |\n|---|---|\n| The client owns the subscription and the master role | Extract and deliver, then remove your users and connections |\n| Your firm owns the subscription or holds the master role | Agree in writing whether the client takes it over or it ends, and ask the vendor what ending your billing does to the client's data; transfer the role and billing, or finish extraction and delivery, before anything is cancelled |\n| Ownership is mixed | Apply the rows above system by system and record each owner |\n\n## What may you tell a successor, and does confidentiality continue?\n\nAnswer a successor only with the client's authority, in the form your rules require:\n\n- **AICPA members.** The Code says a member in public practice shall not disclose confidential client information without the client's specific consent. Where a member withdrew over, for example, irregularities in a client's tax return, it says to suggest that a successor who makes contact ask the client to permit the member to discuss all matters freely, and to seek legal advice; the rule is not intended to help an unscrupulous client hide information by changing CPAs.\n- **California licensees.** California's regulation §54.1 bars disclosing confidential client information without the client's written permission, subject to listed exceptions that include a disclosure made at the client's direct request to a person the client designates at the time of the request.\n- **Tax return preparers.** The Section 7216 FAQ says a taxpayer must provide written consent before a tax return preparer discloses the taxpayer's tax return information, and that a consent contains specific information including the names of the preparer and the taxpayer, the nature of the disclosure, to whom it will be made and the data to be disclosed; is valid only if made knowingly and voluntarily and signed and dated by the taxpayer; and must include certain language and warnings. For the required wording it points to Treas. Reg. §301.7216-3 and Revenue Procedures 2013-14 and 2013-19.\n\nGet the client's written consent naming the successor and what you may share, and share only that. With no successor, deliver the handover to the client and decline voluntary enquiries from anyone the client has not named.\n\nTreat confidentiality as continuing: the AICPA Code applies its consent rule to a successor's contact after a member has withdrawn, and California's §54.1 and the Section 7216 consent rule state no end date. After the exit, do not volunteer information about the client's affairs, reuse their data or keep access in case it is needed.\n\nThe same rules require or allow some disclosures without consent, so do not refuse a lawful demand; take legal advice on any such demand before answering:\n\n| Rule | Disclosure it allows or requires without consent |\n|---|---|\n| AICPA Code | Complying with a validly issued and enforceable subpoena or summons, or with applicable laws and government regulations; responding to an inquiry by a state board's or CPA society's investigative or disciplinary body; information necessary to initiate, pursue or defend yourself in an actual or threatened lawsuit or alternative dispute resolution proceeding |\n| California §54.1 | Compliance with a subpoena or summons enforceable by order of a court; what you reasonably believe necessary to maintain or defend yourself in a legal proceeding the client initiated; a response to an official inquiry from a federal or state government regulatory agency; disclosures specifically required by law |\n| Circular 230 §10.20 | Records or information in any matter before the IRS, submitted promptly on a proper and lawful request by a duly authorized IRS officer or employee, unless you believe in good faith and on reasonable grounds that they are privileged |\n| Section 7216 FAQ | Exceptions in the regulations for certain circumstances, for example disclosures to the IRS, other taxing jurisdictions or the courts, to other U.S.-based tax return preparers that assist in preparing the return (whether that covers a successor firm is not settled by the FAQ), and for obtaining legal advice |\n\n## What should the offboarding record contain?\n\nKeep one dated record showing each item returned, retained, transferred or disabled, with its system, owner, completion date and evidence. For example:\n\n| Item | System | Action | Owner | Completed | Evidence |\n|---|---|---|---|---|---|\n| Exit letter with effective date, scope and deadline owners | Email | Sent | Engagement lead | Oct 3 | Sent message and client's reply |\n| Client-supplied records, adjusting entries and completed returns due for release | Firm document store | Returned | Engagement lead | Oct 10 | Index signed by client |\n| Reports, lists, non-posting transactions and attachments | Client's accounting platform | Exported and delivered | Staff accountant | Oct 10 | Receipt against index |\n| Primary admin role | Client's accounting platform | Transferred to client | Engagement lead | Oct 11 | Client's confirmed sign-in |\n| Subscription billing | Accounting platform | Transferred to client, or ended after delivery | Firm admin | Oct 11 | Vendor billing confirmation |\n| Firm users, shared-folder access, apps, feeds and payment approval | Client's platform, portals and document store | Removed | Firm admin | Oct 12 | Client administrator's screenshot or written confirmation of the user and sharing lists after removal |\n| State tax agency authorization | State agency portal | Withdrawn | Engagement lead | Oct 12 | Agency confirmation |\n| Form 8655 or Form 2678 authorization | IRS | Ended | Engagement lead | Oct 12 | Copy of the filing that ended it |\n| Form 2848 and Form 8821 | IRS | Withdrawn; revoked by client | Enrolled agent | Oct 13 | Annotated copies and fax confirmation |\n| IRS last known address | IRS | Form 8822 or 8822-B filed by client | Engagement lead | Oct 13 | Copy of filed form |\n| Email forwarding rules | Client mail system | Removed by client | Engagement lead | Oct 13 | Client's confirmation |\n| Client portal login and shared links | Firm portal | Disabled | Firm admin | Oct 14 | Portal activity log |\n| Working papers and return copies | Firm archive | Retained | Firm admin | Oct 14 | Archive entry naming the retention rule |\n| Final invoice | Firm billing | Sent | Engagement lead | Oct 14 | Invoice copy |\n| Successor enquiry | Email | Answered within written consent | Engagement lead | Oct 20 | Consent and reply |\n\nKeep the record with the retained file: it is the evidence of what the firm was responsible for and what it gave back.",
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    {
      "id": "REF::11",
      "url": "https://quickbooks.intuit.com/learn-support/en-us/help-article/list-management/export-reports-lists-data-quickbooks-online/L1xleDrLp_US_en_US",
      "title": "Export your QuickBooks Online data",
      "publisher": "Intuit",
      "published": "updated August 3, 2026",
      "retrieved_at": "2026-09-27T12:52:26+00:00",
      "sha256": "5304bb284dff589d3afbb8667e77fd5c212ab7ae6da69967cc5b87a5e7b43057",
      "supports": [
        "C51",
        "C52",
        "C53",
        "C54",
        "C55",
        "C56",
        "C57",
        "C58",
        "C59"
      ]
    },
    {
      "id": "REF::12",
      "url": "https://quickbooks.intuit.com/learn-support/en-us/help-article/access-permissions/happens-quickbooks-online-data-cancel/L6qDpbE1B_US_en_US",
      "title": "What happens to my QuickBooks Online data after I cancel?",
      "publisher": "Intuit",
      "published": "updated August 5, 2026",
      "retrieved_at": "2026-09-27T12:54:32+00:00",
      "sha256": "f8f51bf9e7c253d70df7c8b19cdee2b01d89807abf0da90be85ad667f18bfad7",
      "supports": [
        "C80",
        "C81",
        "C82",
        "C83"
      ]
    }
  ],
  "related": [
    {
      "question_id": "CG-P1B-010",
      "slug": "what-a-bookkeepers-new-client-onboarding-checklist-should-include",
      "display_title": "What should a bookkeeper's new-client onboarding process and document checklist include?"
    }
  ],
  "review_class": "consequential",
  "review_class_trigger": "pre_publication_professional_review_required",
  "provenance": {
    "author_model": "claude-opus-5-5",
    "reviewer_model": "claude-opus-5-5",
    "review_verdict": "ACCEPT",
    "review_source": "closure",
    "review_verdict_on_sha256": "6efbbae76f4ec75b44a58a0764b12b350b059b067d42e448292b0ec6691dbdb9",
    "editorial_disposition": "ACCEPT",
    "corrections": 1,
    "approved_by": null,
    "approved_at": null,
    "article_sha256": "6efbbae76f4ec75b44a58a0764b12b350b059b067d42e448292b0ec6691dbdb9",
    "source_map_sha256": "f45bf5c36f49e943f0ca37268a9d2a5e1e6c80ae887846e16ea0eddd5695eb8f",
    "transform_sha256": "5e5586b0e0f03703164ff9f18d6dfe609d2ecb8a2426a492d9b482ea0158672e"
  },
  "offer": "ask",
  "offer_id": null,
  "sample_target_id": null,
  "datePublished": "2026-09-27T21:10:04Z",
  "reviewed_at": "2026-09-27T21:10:04Z",
  "content_sha": "213b2b0a2972260b3f65bedf96603c525f3284cbe42b3f81a687a5db2d57a6c4",
  "release": "2.11.0",
  "slug_provenance": "minted at first publication",
  "question_text": "How should a bookkeeping or accounting firm offboard a client it is disengaging — what must be handed over, what does the firm keep, and how is access ended?",
  "jsonld_types": [
    "Article"
  ],
  "related_question_ids": [
    "CG-P1B-FULL-005",
    "CG-MCE-118",
    "CG-MCE-132",
    "CG-MCE-138",
    "CG-P1B-010",
    "CG-MCE-121"
  ],
  "aliases": [],
  "alias_provenance": [],
  "notice": "This guide is general information, not tax or legal advice. Confirm with a qualified professional before acting."
}