How to Make Your Accounting Firm Protect Financial Data Using NIST Controls

Learn how accounting firms can safeguard financial data using NIST controls for enhanced security and compliance.

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Reviewed by Jeff Harms

Director, Advisory Services at OCD tech

Updated July, 24

What is NIST

What is NIST Controls for Accounting Firm

NIST Controls for Accounting Firms: A Clear Perspective

 

Accounting firms handle sensitive financial data requiring robust protection. NIST (National Institute of Standards and Technology) controls provide structured security guidance particularly relevant to these organizations.

 

What NIST Controls Mean for Accounting Firms

 

NIST controls are security requirements that help protect your clients' financial information. Think of them as a security checklist designed by cybersecurity experts to keep sensitive data safe. For accounting firms, these controls help protect tax documents, financial statements, and personally identifiable information while maintaining compliance with regulations.

 

NIST Frameworks Most Relevant to Accounting Firms

 

  • NIST SP 800-171 - Specifically addresses protection of controlled unclassified information (CUI), which includes tax information and financial records your firm handles
  • NIST Cybersecurity Framework (CSF) - Provides a flexible structure that helps accounting firms organize their security efforts around five core functions: Identify, Protect, Detect, Respond, and Recover
  • NIST SP 800-53 - While designed for federal systems, many accounting firms handling government contracts or seeking higher security maturity adopt these more comprehensive controls

 

Key NIST Control Areas for Accounting Firms

 

  • Access Management Controls - Ensure only authorized staff can access client financial records and tax documents
  • Data Protection Controls - Require encryption of sensitive financial information both in storage and during transmission
  • Audit Logging - Track who accessed financial records, when, and what changes were made
  • Secure Client Communications - Protect tax documents and financial statements when sharing with clients
  • Secure Remote Access - Critical for accounting staff working remotely with financial systems during tax seasons
  • Third-Party Risk Management - Address security requirements for accounting software providers and cloud services holding financial data

 

Business Benefits for Accounting Firms

 

  • Client Trust Enhancement - Demonstrate to clients that their financial information is protected using nationally-recognized standards
  • Regulatory Alignment - NIST controls help satisfy requirements from IRS Publication 1075, SEC regulations, and state-level data protection laws affecting financial information
  • Breach Prevention - Systematically reduce the risk of financial data breaches during high-value periods like tax season
  • Competitive Advantage - Position your accounting practice as security-conscious in an industry where data protection increasingly matters to clients

 

Practical Implementation Approach

 

For accounting firms new to NIST, begin with the Cybersecurity Framework to establish fundamental protections for client financial data. As your security program matures, incorporate NIST SP 800-171 controls specifically targeting the protection of sensitive financial information. This progressive approach balances immediate security needs with long-term compliance objectives.

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NIST Controls Main Criteria for Accounting Firm

Explore NIST controls as key criteria for accounting firms, ensuring compliance, security, risk management, and data protection in financial services.

Access Control Management

Data Protection & Confidentiality

Audit Logging & Monitoring

Incident Response Planning

Secure Configuration Management

Third-Party Risk Management

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Challenges Accounting Firm Face When Meeting NIST Controls

Explore key challenges accounting firms face when meeting NIST controls, including compliance, cybersecurity, risk management, and regulatory requirements.

Sensitive Client Data Protection

 

  • Accounting firms manage exceptionally sensitive financial data that requires protection beyond standard NIST controls, including tax returns, financial statements, and personally identifiable information (PII) of high-net-worth individuals and corporate executives
  • Implementing NIST SP 800-53 controls like AC-3 (Access Enforcement) and SC-28 (Protection of Information at Rest) requires specialized configurations for tax preparation and accounting software that aren't addressed in standard implementation guidance
  • Firms must develop custom data classification schemes that align both with NIST requirements and professional accounting standards, creating potential conflicts between technical controls and professional requirements

Seasonal Operational Fluctuations

 

  • Accounting firms experience dramatic workload variations during tax seasons, creating unique challenges for implementing consistent access controls (AC-2) and audit logging (AU-2) when temporary staff and processing volumes spike
  • Remote access requirements increase substantially during peak periods, making continuous monitoring controls (CA-7) and remote access protections (AC-17) particularly difficult to maintain at consistent levels
  • Firms must balance operational efficiency during high-demand periods with security requirements, a tension not addressed in NIST's more steady-state operational assumptions

Third-Party Software Dependencies

 

  • Accounting firms rely on specialized tax and financial software that often cannot be modified to meet specific NIST controls around authentication (IA-2) or system and communications protection (SC-8)
  • These firms must develop compensating controls for vendor software that may not meet federal standards but is essential for core business operations
  • The integration between multiple financial platforms creates complex system boundaries that complicate implementation of system and information integrity controls (SI family) and boundary protection (SC-7)

Regulatory Crossover Complexity

 

  • Accounting firms must reconcile multiple overlapping requirements from NIST, IRS Publication 1075, AICPA professional standards, and financial regulations
  • Documentation must demonstrate how single control implementations satisfy multiple regulatory frameworks, creating significant administrative overhead
  • The interpretation of NIST controls in accounting contexts lacks specific guidance, requiring firms to make risk-based decisions that may be questioned during assessments without industry-specific precedents

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Guide

How to Make Your Accounting Firm Protect Financial Data Using NIST Controls

How to Make Your Accounting Firm Protect Financial Data Using NIST Controls

 

Accounting firms handle some of the most sensitive financial data for their clients. From tax returns to payroll information, bank statements to investment portfolios, this data requires robust protection against increasingly sophisticated cyber threats. The National Institute of Standards and Technology (NIST) provides frameworks that can be specifically tailored to protect your accounting firm's sensitive information. Let's explore how to implement these controls in ways that address the unique challenges of accounting firms.

 

Understanding NIST for Accounting Firms

 

NIST frameworks are sets of guidelines, not rigid checklists. For accounting firms, the most relevant framework is the NIST Cybersecurity Framework (CSF), which organizes security controls into five key functions: Identify, Protect, Detect, Respond, and Recover. Additionally, NIST Special Publication 800-53 provides detailed security controls that can be mapped to accounting-specific needs.

 

Step 1: Identify Your Accounting Firm's Critical Assets

 

  • Client financial data: Tax returns, financial statements, bank account information
  • Authentication credentials: Access to client portals, financial institutions, tax authority websites
  • Accounting software: QuickBooks, Xero, Sage, proprietary systems
  • Client communication: Email exchanges containing financial details, documentation requests
  • Staff workstations: Computers where financial data is processed and analyzed
  • Backup systems: Where copies of client financial records are stored

 

Step 2: Implement Core NIST Controls for Accounting Firms

 

Data Classification & Handling

 

  • Create a tiered system for financial data (highly confidential, confidential, internal use, public)
  • Label client tax documents as highly confidential and apply stricter controls
  • Develop specific handling procedures for data like Social Security numbers, bank account details
  • Implement appropriate restrictions on who can access particular client files

 

Access Control for Financial Information

 

  • Enforce role-based access control (RBAC) where junior accountants cannot access all client files
  • Implement segregation of duties where multiple approvals are needed for financial transactions
  • Use multi-factor authentication (MFA) for all access to client financial systems and data
  • Conduct quarterly access reviews to ensure terminated employees no longer have access to client data
  • Create specific procedures for tax season temporary staff to limit their access appropriately

 

Secure Communication with Clients

 

  • Implement a secure client portal for exchanging tax documents and financial information
  • Use encrypted email when sending sensitive financial documents
  • Establish clear policies prohibiting the use of personal email for client communications
  • Create procedures for securely sending tax returns, financial statements, and other deliverables
  • Develop authentication protocols for confirming client identity before sharing sensitive information

 

Secure Configuration of Accounting Software

 

  • Maintain secure configurations for tax preparation software, accounting packages, and financial tools
  • Disable unnecessary features in accounting applications that could create security vulnerabilities
  • Regularly update and patch all financial software systems
  • Implement application whitelisting to prevent unauthorized software on systems handling financial data
  • Conduct security reviews when implementing new accounting tools or systems

 

Step 3: Protecting Data in Transit and at Rest

 

Data Encryption

 

  • Encrypt all stored client financial records using FIPS 140-2 validated encryption
  • Use TLS 1.2 or higher for all web-based accounting applications
  • Implement encrypted backup solutions for all client tax files and financial statements
  • Deploy encrypted drives on all devices that store or process client financial information
  • Utilize secure file transfer protocols when exchanging data with clients or third parties

 

Mobile Device Management

 

  • Create specific policies for accountants accessing client data on mobile devices
  • Require encryption and passcodes on all mobile devices used by accounting staff
  • Implement remote wipe capabilities for lost or stolen devices containing client financial data
  • Restrict the downloading of sensitive financial information to mobile devices when possible
  • Deploy mobile device management (MDM) solutions for all firm-owned devices

 

Step 4: Detection and Monitoring for Accounting Firms

 

Audit Logging for Financial Systems

 

  • Enable comprehensive audit logging for all accounting software and financial applications
  • Record all access to tax returns and sensitive client financial records
  • Monitor unusual access patterns such as staff accessing client files outside of normal engagement periods
  • Track changes to tax calculations and financial statements
  • Preserve logs for a period that aligns with record retention requirements for financial data

 

Threat Detection

 

  • Deploy specialized monitoring for accounting-specific threats like tax fraud schemes
  • Implement checks for unauthorized modifications to financial records
  • Establish alerts for unusual data exports of client financial information
  • Monitor for suspicious login attempts to tax preparation systems
  • Create baselines of normal activity patterns during different accounting cycles (tax season vs. other periods)

 

Step 5: Incident Response for Financial Data Breaches

 

  • Create accounting-specific incident response procedures that address tax data exposure
  • Develop notification templates for different types of financial data breaches
  • Establish coordination procedures with financial institutions if client banking data is compromised
  • Include steps for IRS notification if tax data is exposed
  • Conduct tabletop exercises simulating financial data breach scenarios
  • Document chain-of-custody procedures for evidence related to financial fraud

 

Step 6: Business Continuity for Accounting Operations

 

  • Develop recovery time objectives (RTOs) specific to different accounting functions
  • Create more stringent recovery procedures for tax filing systems during tax season
  • Implement redundant systems for critical financial applications
  • Establish backup procedures with increased frequency during peak financial reporting periods
  • Test restoration procedures for client financial data regularly
  • Create alternative processing procedures if primary systems are unavailable during critical deadlines

 

Step 7: Third-Party Risk Management for Accounting Firms

 

  • Assess security controls of tax software providers and financial application vendors
  • Review security practices of client portal providers and document storage services
  • Establish security requirements for payroll processors and other financial service providers
  • Conduct due diligence on cloud providers storing financial records
  • Include right-to-audit clauses in contracts with providers handling sensitive financial data

 

Step 8: Employee Security Awareness with Accounting Focus

 

  • Provide specialized training on tax-related phishing schemes
  • Educate staff on social engineering techniques targeting accounting professionals
  • Conduct scenario-based training on handling client financial data properly
  • Create awareness materials about current financial fraud tactics
  • Develop specific guidance for seasonal tax preparers on security protocols

 

Step 9: Compliance Integration

 

  • Map NIST controls to IRS Publication 4557 (Safeguarding Taxpayer Data) requirements
  • Align security practices with AICPA guidance on information security
  • Ensure controls satisfy Gramm-Leach-Bliley Act requirements for financial data
  • Document how NIST controls help meet state data breach notification laws for financial information
  • Create a crosswalk between NIST CSF and accounting industry best practices

 

Step 10: Continuous Improvement

 

  • Conduct annual security assessments focused on protection of financial data
  • Perform penetration testing targeting accounting systems and client portals
  • Review security controls after each major tax season
  • Update security practices based on emerging threats to financial information
  • Benchmark security practices against other accounting firms of similar size

 

Practical Implementation Steps for Small to Medium Accounting Firms

 

  • Start with the most critical data: Focus first on protecting tax returns, banking information, and personally identifiable information
  • Implement in phases: Begin with the basic NIST controls and gradually add more sophisticated protections
  • Use cloud solutions: Leverage accounting-specific cloud providers that already implement many NIST controls
  • Consider managed services: Partner with cybersecurity providers who understand accounting industry requirements
  • Join information sharing groups: Participate in accounting industry security forums to stay current on threats

 

Common NIST Implementation Challenges for Accounting Firms

 

  • Balancing security with efficiency: Implementing controls that protect financial data without slowing down critical processes during tax deadlines
  • Managing seasonal workforce: Providing appropriate access and security training to temporary tax preparation staff
  • Client expectations: Educating clients on secure methods for sharing financial information
  • Legacy accounting systems: Securing older financial applications that may lack modern security features
  • Resource constraints: Implementing comprehensive security with limited IT staff and budget

 

By systematically implementing these NIST-based controls with an accounting-specific focus, your firm can significantly improve the protection of sensitive financial data. Remember that cybersecurity is not a one-time project but an ongoing process of improvement. Each tax season and financial reporting cycle presents an opportunity to review and enhance your security posture, ensuring that your clients' most sensitive financial information remains protected.

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Frequently asked questions

What services does OCD Tech provide?

OCD Tech offers a comprehensive suite of cybersecurity and IT assurance services, including SOC 2/3 and SOC for Cybersecurity reporting, IT vulnerability and penetration testing, privileged access management, social engineering assessments, virtual CISO (vCISO) support, IT general controls audits, WISP development, and compliance assistance for frameworks like CMMC, DFARS, and FTC Safeguards.

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OCD Tech specializes in serving highly regulated sectors such as financial services, government, higher education, auto dealerships, enterprise organizations, and not-for-profits throughout New England.

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Typically, OCD Tech’s on-site work spans 1–2 days, depending on complexity and number of sites, followed by 1–2 weeks of analysis and reporting to deliver clear, actionable recommendations.

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Can OCD Tech help me with federal cybersecurity regulations?

Yes—OCD Tech provides guidance for compliance with DFARS (NIST 800‑171), CMMC (Levels 1–3), and FTC Safeguards, ensuring organizations meet specific government or industry-based cybersecurity mandates.

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A virtual CISO delivers strategic, executive-level cybersecurity leadership as a service. OCD Tech’s vCISO service is ideal for organizations lacking a full-time CISO and helps build programs, define policy, oversee risk, and guide security maturity.

Does OCD Tech offer ongoing security training or audits for staff?

Absolutely. OCD Tech provides tailored internal IT Audit training and security awareness sessions, plus annual reviews of Written Information Security Programs (WISP), such as Massachusetts 201 CMR 17 and other state or industry-specific controls.