Oct 105 min read

Compliance

Compliance for client calculators: what CPAs, EAs and advisers should check

How Circular 230, the AICPA Code, the SEC Marketing Rule, FINRA Rules 2210 and 2214 and IRC §7216 apply when a firm puts calculators on its website.

By NumbersForClients Editorial Desk · Published · Updated

Key points

Key takeaways

  • A calculator on your site is part of your advertising: keep it accurate and free of promises.
  • Your written reply to a calculator request is professional advice and carries the usual standards.
  • RIAs: client-run tools with disclosed methodology are treated differently from adviser-presented projections.
  • Keep lead data and tax return data separate; §7216 governs the latter.
  • This guide is general information. Your compliance officer or counsel makes the call for your firm.

Putting a calculator on your website is a small technical step and a real compliance one. The calculator becomes part of your advertising, the requests it produces lead to written advice, and for advisers the outputs may be projections. None of this is a reason not to do it. It is a reason to set it up carefully.

This guide summarizes the rules that usually come up for compliance for client calculators. It’s general information, not legal advice; your compliance officer or counsel decides how it applies to your firm.

Three questions to ask about any calculator

  1. Is the calculator itself accurate and honestly labeled? That’s an advertising question.
  2. What happens when we reply to a request? That’s a professional-standards question.
  3. Where does the client’s data go? That’s a privacy and confidentiality question.

For CPAs, EAs and other tax practitioners

Circular 230 §10.30: advertising

Circular 230 (31 CFR Part 10) governs practice before the IRS. Section 10.30 prohibits false, fraudulent, coercive, misleading or deceptive statements in solicitation and advertising. For calculators, the practical points are:

  • Title and button text. “Estimate your 2026 federal tax” is accurate. “See your refund” or “Maximum refund guaranteed” is not.
  • Limits stated. If a calculator ignores state tax or AMT, say so near the result.
  • Current figures. A calculator showing last year’s limits under your name is misleading by accident. Use tools whose figures are sourced and dated; ours are listed on the 2026 figures page.

Circular 230 §10.37: written advice

Section 10.37 requires written advice to be based on reasonable factual and legal assumptions, to consider all relevant facts the practitioner knows or reasonably should know, and not to rely unreasonably on representations. The 2014 amendments removed the old covered-opinion rules, and with them the reason for boilerplate email disclaimers.

What this means for calculator requests: the calculator’s output is arithmetic on the client’s inputs. Your reply is advice. Before you write “you should convert $40,000 to a Roth this year”, consider what the calculator didn’t: other income, Medicare premium thresholds, state tax. A good reply template says what you’ll need to confirm.

The AICPA Code and state boards

The AICPA Code of Professional Conduct’s advertising and other forms of solicitation rule (ET 1.600.001) prohibits false, misleading or deceptive advertising. State boards of accountancy have their own rules. Independence considerations apply if you provide attest services to a client and advise them on decisions a calculator informs.

IRC §7216: return information

Section 7216 restricts how tax return preparers use and disclose return information. A prospect’s calculator inputs aren’t return information. But once you prepare a client’s return, using return information to market other services (for example, using their AGI to suggest a planning engagement) generally requires written consent under the Treasury regulations. Keep calculator leads in your CRM and return data in your tax system, and get consents where needed.

For registered investment advisers

The SEC Marketing Rule

Rule 206(4)-1 under the Investment Advisers Act (compliance date November 4, 2022) governs adviser advertisements. Projections of performance can be hypothetical performance, which requires policies and procedures reasonably designed to ensure it’s relevant to the likely financial situation and objectives of the intended audience, plus disclosures about criteria, assumptions and risks.

The adopting release discusses interactive analysis tools that clients use to produce their own simulations. It treats them differently from adviser-presented hypothetical performance, provided the adviser:

  • describes the criteria and methodology used, including limitations and key assumptions;
  • explains that results may vary with each use and over time;
  • discloses, where applicable, the universe of investments considered and that the tool may favor certain investments.

Practical steps for retirement and investment calculators:

Step Why
Let the client choose return and inflation assumptions The client produces the scenario
Document how default values were chosen Your CCO can review them
Show methodology and limitations on the page Matches the disclosures expected
Don’t link a projection to a specific product Avoids turning education into a recommendation
Archive the pages as published Books-and-records

State-registered advisers follow their state’s rules, which often draw on similar principles.

Testimonials and reviews

The Marketing Rule permits testimonials and endorsements with disclosures and oversight. We don’t supply any; if you add reviews to a calculator page, they follow your firm’s process.

For broker-dealer representatives and dual registrants

FINRA Rule 2210 governs communications with the public and generally prohibits predictions or projections of performance. Rule 2214 creates an exception for investment analysis tools, with requirements including a description of the tool’s criteria and methodology, its limitations and key assumptions, and a statement that results may vary with each use and over time. Dual registrants need to satisfy both regimes; clear any projection calculator with your broker-dealer’s compliance department first.

  • Consent at the form. The lead form should say how you’ll use the details and link your privacy notice.
  • Your privacy notice. Mention calculator enquiries and follow-up.
  • State privacy laws. Clients in states with comprehensive privacy laws may request access or deletion; delete the contact in the calculator platform and in any CRM a webhook fed.
  • Spanish-speaking clients. If you offer Spanish calculators, consider whether your notices should be available in Spanish too.

See our security and privacy overview for how lead data is handled on our side.

A pre-launch checklist

  • Calculator titles and buttons describe estimates, not outcomes
  • Limits and tax year visible near results
  • Disclaimer reviewed and adapted to your firm
  • Reply template reviewed for §10.37 (tax) or suitability (advisers)
  • For RIAs: methodology, assumptions and variability explained; CCO sign-off
  • For dual registrants: broker-dealer approval under Rule 2214
  • Lead form consent and privacy link in place
  • Pages archived per your records policy

Our calculators are built to make this list shorter: definitions and disclaimers are in every calculator, figures are sourced, and limits are stated on every calculator page. The judgment, as always, stays with your firm.

Sources
NumbersForClients mark
NumbersForClients Editorial Desk
Guides for accounting and advisory firms

The in-house desk that writes our guides on client self-service, tax-season lead capture and compliance for client calculators.

Guides are written from public IRS, SSA, SEC, FINRA and AICPA sources, cited in each article. They are not reviewed by a named CPA, EA or attorney yet.

FAQ

Questions about this guide

Showing 8 of 8
  • Do we still need a Circular 230 disclaimer on emails?

    The 2014 amendments removed the covered-opinion rules that drove that boilerplate. What matters now is that written advice meets §10.37 and that advertising isn't misleading under §10.30.

  • Is a calculator result 'written advice' under Circular 230?

    A tool that does arithmetic on the client's inputs is generally not your advice. Your reply interpreting the result for that client usually is.

  • Are retirement projections hypothetical performance?

    When an adviser presents them, they can be. The SEC's adopting release treats interactive tools clients use themselves differently, if the adviser provides specific explanations.

  • Can broker-dealer representatives use projection calculators?

    FINRA Rule 2210 generally prohibits projections, and Rule 2214 permits investment analysis tools with specific disclosures. Check with your broker-dealer first.

  • Does §7216 apply to calculator leads?

    A prospect's calculator inputs aren't tax return information. Once you prepare their return, using return information for other services generally requires written consent.

  • What should the calculator disclaimer say?

    That results are estimates from the user's inputs, what the calculator leaves out, the tax year of the figures, and that it isn't tax, legal or investment advice.

  • Do state boards of accountancy have extra rules?

    Many have advertising rules of their own. Check your state board's regulations.

  • Should we keep copies of calculator pages?

    Advisers subject to books-and-records rules should archive advertisements, including web pages, as their policies require.

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