What AICPA and State Boards Actually Require for Accountant Advertising — And What They Don't

AICPA Code of Professional Conduct Section 1.600 addresses advertising and solicitation for CPAs. The core principle is straightforward: members shall not seek to obtain clients by advertising or other forms of solicitation in a manner that is false, misleading, or deceptive.

What Section 1.600 specifically prohibits:

• Creating false or unjustified expectations of favorable results
• Implying the ability to influence any court, tribunal, regulatory agency, or similar body
• Containing representations that would cause a reasonable person to misunderstand or be deceived
• Making claims that cannot be substantiated

What Section 1.600 does not prohibit:

• Search engine optimization for your website
• Content marketing about accounting topics
• Listing services, credentials, and experience
• Maintaining Google Business Profile presence
• Requesting reviews from satisfied clients (without improper incentives)

The rule targets the substance of claims, not the marketing channel. SEO itself is not addressed—what matters is whether the content on your website makes truthful, substantiated claims. A well-optimized service page describing your tax preparation services is compliant. A page claiming "designed to audit protection" or "we always save clients money" would violate truthfulness standards regardless of whether it's optimized for search.

Note: This is educational content, not legal or professional conduct advice. Verify current interpretations with AICPA and your state board.

The Federal Trade Commission's Endorsement Guidelines apply to all businesses, including accounting firms. These rules govern how you can use client testimonials, case studies, and reviews in your marketing.

Core FTC requirements for accountant testimonials:

• Testimonials must reflect honest opinions and actual experiences
• Material connections must be disclosed (if you provided any incentive, discount, or benefit for the testimonial)
• Results mentioned should be typical, or you must clearly disclose what the typical consumer would experience
• You cannot use testimonials that make claims you couldn't make directly

For accounting firms, this affects several SEO elements:

Google reviews: Soliciting reviews is permitted. Offering incentives (discounts, gifts, entries into drawings) for reviews is problematic under FTC guidelines and often violates platform terms of service. Ask for reviews—don't pay for them.

Website testimonials: If a client quote mentions specific savings or outcomes ("saved us $50,000 in taxes"), you should either verify this is typical or add appropriate context ("Results vary based on individual circumstances").

Case studies: Detailed client success stories require careful framing. Include enough context that readers understand results may not be typical. Avoid presenting outlier outcomes as standard expectations.

The FTC updated these guidelines in 2023 to strengthen requirements around reviews and endorsements. When featuring client results on your website, err on the side of more disclosure rather than less.

State CPA boards regulate advertising independently, and rules vary more than many accountants realize. While most states follow AICPA standards as a baseline, several impose additional requirements.

Common state-level variations:

• Specialization claims: Some states require specific credentials or experience thresholds before you can advertise as a "specialist" in any area. Texas, for example, has historically required meeting defined criteria before using specialization language.
• Fee advertising: Most states now permit fee advertising, but some require specific disclosures or prohibit certain comparative fee claims.
• Firm name requirements: Rules about using terms like "& Associates" or "Group" when you're a solo practitioner vary by state.
• Testimonial restrictions: A few states have rules about testimonials that go beyond FTC requirements.

States with notably stricter or unique rules (as of 2024—verify current status):

• California: Specific rules about advertising specialization
• Texas: Detailed advertising rule interpretations
• New York: Additional requirements for certain claims
• Florida: Specific solicitation restrictions

For multi-state firms, compliance means meeting the requirements of every state where you hold a license and serve clients. Your website reaches all jurisdictions—a claim compliant in one state may violate rules in another.

Practical step: Download your state board's current advertising rules (usually available on their website) and review them against your website content annually. Rules change, and staying current is your responsibility.

This overview is educational. State board rules change frequently—always verify current requirements directly with your licensing authority.

Most standard SEO practices are fully compliant with accounting advertising rules. The key is ensuring the content being optimized meets truthfulness standards.

Compliant SEO activities:

• Technical SEO: Site speed, mobile optimization, structured data, crawlability—none of these involve advertising claims
• Local SEO: Google Business Profile optimization, local citations, NAP consistency—compliant as long as business information is accurate
• Content marketing: Educational blog posts, guides, and resources about accounting topics—compliant when information is accurate and doesn't make improper claims about your services
• Service page optimization: Describing your services accurately with relevant keywords—compliant
• Link building through expertise: Guest articles, industry contributions, speaking engagements—compliant and actually demonstrates legitimate expertise

Where compliance issues arise:

• Service pages claiming designed to outcomes
• Testimonial sections without proper context for atypical results
• "Best CPA in [City]" claims without substantiation
• Specialization claims without meeting state-specific requirements
• Competitor comparison content making unsubstantiated claims

The solution isn't to avoid SEO—it's to audit your website content for compliance issues before amplifying it through optimization. A compliant page that ranks well serves your firm. A non-compliant page that ranks well creates risk.

Understanding how compliance issues surface helps you prioritize risk management. Most violations aren't discovered by regulators actively searching—they come from complaints.

Common triggers for advertising complaints:

• Competitor complaints: A competing firm sees your website claiming something questionable and files a complaint with the state board
• Disgruntled former clients: A client unhappy with outcomes reviews your marketing materials and reports perceived misrepresentations
• Regulatory review: During license renewal or random audit, boards may review your public marketing presence

Typical enforcement process:

1. Complaint received by state board
2. Initial review to determine if complaint has merit
3. Request for response from the licensee
4. Investigation if warranted
5. Resolution ranging from requiring changes to formal disciplinary action

Consequences vary by severity:

• Minor issues: Warning letter, required website changes
• Moderate issues: Public reprimand, continuing education requirements
• Serious or repeated issues: Fines, license suspension, or revocation

In our experience working with accounting firms, the most common issues we see are over-claiming expertise (using "specialist" language without credentials) and results claims without context (featuring client savings without noting results vary). Both are easily avoided with careful website review.

The risk isn't that SEO itself draws regulatory attention—it's that effective SEO makes more people see your website, including competitors and regulators. Higher visibility means higher scrutiny of your claims.

Before investing in SEO, conduct a compliance review of your existing website content. This protects you from amplifying problematic content and provides a clean foundation for optimization.

Review these elements:

Homepage and service pages:

• Are all service descriptions accurate and substantiated?
• Do you claim specializations? If so, do you meet your state's requirements for that claim?
• Any language implying designed to outcomes or "always" delivering specific results?
• Superlative claims ("best," "leading," "top") that can't be verified?

Testimonials and reviews section:

• Do testimonials include specific results claims? If so, are they typical or disclosed as atypical?
• Were any incentives provided for testimonials? If so, is this disclosed?
• Are testimonials from real clients (not fabricated)?

About and team pages:

• Are credentials accurately stated?
• Are affiliations and certifications current?
• Does firm name comply with your state's naming rules?

Blog and resource content:

• Is tax or financial advice appropriately framed as educational rather than individualized guidance?
• Are statistics and claims sourced or qualified?
• Disclaimers present where needed?

Document your review and any changes made. This creates a record of good-faith compliance efforts if questions ever arise. For firms with substantial content, consider having an attorney familiar with CPA advertising rules conduct a formal review before major marketing investments.