Skip to content

IRS requires a Written Information Security Plan — is your firm compliant?

Free Compliance Review
Publication 4557 | FTC Safeguards Rule | GLBA

IRS Compliance Simplified for Tax Preparers

Publication 4557, FTC Safeguards Rule, WISP certification, Security Six — four overlapping frameworks, one managed solution. Bellator handles all of it so you can focus on your clients.

4
Compliance Frameworks

IRS Pub 4557, FTC Safeguards, GLBA, and WISP — all required, all overlapping

2024
WISP Attestation Required

PTIN renewal now requires Written Information Security Plan attestation

$100K+
Per Violation Fine

FTC Safeguards Rule violations can exceed $100,000 per incident

100%
Must Comply

Every tax preparer, CPA, EA, and bookkeeper — no size exemptions

Why IRS Compliance Is So Confusing

Tax professionals face four overlapping cybersecurity frameworks — each with different requirements, different enforcement agencies, and different penalties. Miss one and you risk fines, PTIN revocation, or worse.

IRS Publication 4557

Security Six protections, WISP requirement, vendor vetting, incident response planning, staff training

FTC Safeguards Rule

9 mandatory controls — encryption, MFA, access controls, Qualified Individual, continuous monitoring

WISP Requirement

Written Information Security Plan — mandatory for PTIN renewal since 2024, must be maintained and updated annually

GLBA / Gramm-Leach-Bliley

Federal law requiring all "financial institutions" to protect customer data — the legal backbone behind FTC enforcement

The good news: there's significant overlap. One well-designed security program satisfies all four. That's exactly what Bellator delivers.

What Bellator Handles for You

One managed service covering every IRS, FTC, and GLBA requirement

WISP Creation & Maintenance

We write your IRS-compliant Written Information Security Plan, keep it updated annually, and ensure it satisfies both IRS and FTC requirements.

Security Six Implementation

Antivirus, firewalls, MFA, encryption, drive wiping, and access controls — all six IRS-required protections deployed and managed.

Qualified Individual

We serve as your designated Qualified Individual for FTC Safeguards Rule compliance — no need to hire a security expert in-house.

Continuous Monitoring

24/7 threat monitoring, log management, and automated alerts catch issues before they become breaches or compliance failures.

Staff Security Training

Annual cybersecurity awareness training for your team — covering phishing, social engineering, and data handling per IRS Publication 4557.

Incident Response Planning

A tested, documented incident response plan ready to execute if a breach occurs — meeting both IRS and FTC response requirements.

How It Works

From compliance gap to fully covered in as little as 30 days

1

Compliance Audit

We assess your practice against all four frameworks, identify every gap, and build a prioritized remediation plan.

2

Implementation

Our team deploys the required controls, writes your WISP, configures Security Six protections, and trains your staff.

3

Ongoing Management

Year-round monitoring, annual WISP updates, risk reassessments, and PTIN-ready documentation — always audit-ready.

What Happens If You Don't Comply

PTIN Revocation

IRS can revoke your PTIN and e-filing privileges — no WISP attestation means no PTIN renewal

$100K+ Fines

FTC Safeguards violations carry penalties exceeding $100,000 per violation — each client record counts

Client Lawsuits

A data breach without proper safeguards exposes you to lawsuits, state AG action, and reputational damage

We had no idea how many compliance frameworks applied to our practice. Bellator consolidated everything into one program — WISP, FTC, Security Six — and we haven't thought about it since.

SP
Senior PartnerEnrolled Agent at Midwest Tax Associates

IRS Compliance — Frequently Asked Questions

IRS Publication 4557 is the IRS's guidance document for tax professionals on protecting taxpayer data. It covers the Security Six protections, WISP requirements, vendor management, and incident response planning. Compliance is tied to your PTIN and e-filing privileges.

The FTC Safeguards Rule is a federal regulation under the Gramm-Leach-Bliley Act requiring specific technical controls — encryption, MFA, access controls, monitoring, and a designated Qualified Individual. It carries civil fines exceeding $100,000 per violation. Both are required, but they overlap significantly. A well-designed compliance program covers both simultaneously.

Yes. There are no size exemptions. Whether you're a solo enrolled agent or a 50-person CPA firm, you must comply with IRS Publication 4557, the FTC Safeguards Rule, and maintain a current WISP for PTIN renewal. The FTC defines any business handling consumer financial information as a "financial institution" — that includes every tax preparer regardless of firm size.

The Security Six are six foundational protections required by IRS Publication 4557: (1) antivirus software on all devices, (2) hardware and software firewalls, (3) multi-factor authentication, (4) encryption for data in transit and at rest, (5) secure drive wiping before disposal, and (6) access controls limiting who can view taxpayer data.

These form the baseline of IRS compliance. The FTC Safeguards Rule adds additional requirements on top — continuous monitoring, a Qualified Individual, formal risk assessments, and documented change management.

Your WISP should be reviewed and updated at least annually, and any time there is a material change to your systems, staff, or data handling practices. The IRS expects your WISP to reflect your current operations — not a static document written once and forgotten.

Bellator's managed program includes annual WISP reviews and updates as part of the service — so your plan always reflects your current environment and meets the latest requirements.

That's exactly what we do. Because IRS Publication 4557, the FTC Safeguards Rule, GLBA, and the WISP requirement share significant overlap, Bellator delivers a single managed compliance program that satisfies all four. You get one point of contact, one security program, and complete coverage.

Our program includes WISP creation and maintenance, Security Six implementation, FTC-required controls, Qualified Individual services, staff training, and 24/7 monitoring — everything you need to stay compliant year-round.

Protect your tax practice from cyber threats

Schedule a free consultation to assess your firm's security posture.