Accounting and tax Compliance and accessibility By Partha Biswas and Deepti Karn Last updated on October 13, 2026 7 min read

Data security plan for tax preparers: the client upload path belongs in it

A written information security plan page with the client upload page listed in its scope

Every paid preparer renewing a PTIN signs Form W-12, which says preparers are required by law to keep a written information security plan covering "all taxpayer information." The IRS sample plan in Publication 5708 walks through hardware, the office network and the tax software. It never names the firm's website. If clients upload returns, IDs and statements through a page on your site, does the plan have to say anything about that page?

TL;DR

Yes: a data security plan for tax preparers should cover the upload page if client files reach the firm through its own website, and it should say how that page is maintained and by whom. No IRS text names the website, so this follows from the scope covering all taxpayer information, and a firm whose uploads run through a separate portal vendor may need little more than a line naming that vendor, with the Qualified Individual making the call. The Pub 5708 template’s inventory step is “Inventory Hardware,” so a hosted web page is easy to leave out. If the upload page runs on WordPress, the plan needs a named maintainer, and NoDrama’s website maintenance for accounting firms shows how that is set up.

Contents

  1. 01
    Work out what the plan has to cover
    The short answerHow the written plan is built
  2. 02
    Find the upload page in it
    Why it sits inside the scopeWhat the plan records about it
  3. 03
    Write it in and keep it true
    Adding the upload pathCommon misreadingsWhat this does not solveThe conclusion

Does a data security plan for tax preparers have to cover the website?

Yes, when client files reach the firm through its own site. The plan’s scope is “all taxpayer information,” and the upload page carries taxpayer information, so the page belongs in the plan. The step from that scope language to the website is our reading of it, not an IRS sentence.

Two cases need little or nothing.

Uploads through your own siteThe page belongs in the plan.
Brochure-only siteWith no client data path, it is out of scope.
Separate portal vendorWhere uploads run entirely through it, the plan may need a line naming that vendor.

How the written plan is built, and where the rule comes from

The rule behind the attestation

The IRS Security Summit release IR-2025-79, dated July 29, 2025, says “The Gramm-Leach-Bliley Act (GLBA) requires all financial institutions to protect customer data,” and that “tax and accounting professionals are considered financial institutions.” The regulation is the FTC Safeguards Rule, 16 CFR Part 314.

Form W-12 (Rev. 10-2025), line 11, carries the attestation:

Form W-12, line 11

“I am aware that paid tax return preparers are required by law to create and maintain a written information security plan … that provides data and system security protections for all taxpayer information.”

The wording is “I am aware.” It attests awareness, not that the plan is complete or covers any particular system.

The IRS template, Publication 5708

Publication 5708 (Rev. 8-2024) is the IRS template. The IRS term is WISP, short for written information security plan, and this is the IRS WISP. It sets out seven steps:

Step IV is hardware. A hosted web page is not obviously prompted by that step, so a template filled in step by step can be finished without listing the upload page. That is our reading of the template, not an IRS statement. Pub 5708 does not name websites or upload pages as such.

Why the client upload page sits inside the plan’s scope

The IRS documents already use web wording.

Publication 5708

Refers to “Online (Web-based) applications, portals, and cloud software applications such as Box.” It also says “The Firm may use a Password Protected Portal to exchange documents containing PII upon approval.”

Publication 4557

Names websites twice: “If hosting your own website, also consider some other form of multifactor authentication” and “If you collect information online directly from customers, make secure transmission automatic.”

Safeguards Rule, 314.4(b)(1)

Says “The risk assessment shall be written and shall include:” and in our reading, a system that holds client files belongs in it.

Read Publication 4557 (Rev. 6-2024) in full for the website lines.

Pub 5708 exempts tax software vendors and e-Filing transmitters from its third-party limits. That exemption does not reach a separately hosted website. To see what state the site is in, start with how to check whether your website is secure.

What the plan says about the upload page when it covers it

Which of these the firm does is for the firm and its Qualified Individual to decide.

The FTC notification rule in 314.4(j) belongs in the incident row. From the Federal Register notice:

Applies where the event involves the information of at least 500 consumers.
Notice goes to the FTC as soon as possible, and no later than 30 days after discovery.
Effective as of May 13, 2024.
314.2(m), notification event

“acquisition of unencrypted customer information without the authorization of the individual to which the information pertains.”

See how NoDrama approaches WordPress security.

How to add the upload path to your plan

Five edits, one line each:

  1. 01

    Name the upload page in the Scope section and in the list of places PII is stored.

  2. 02

    Name who maintains the site it sits on, and whether that is a service provider under 314.4(f).

  3. 03

    Record how logins to the site work, including MFA.

  4. 04

    Record how files travel and where they land.

  5. 05

    Record what is monitored and what happens on an incident, pointing to the firm’s incident response plan.

Where the site runs on WordPress, the maintenance can be written into the plan as a procedure. NoDrama’s plans include “WordPress, plugins and themes kept current,” “Scanned for malware every 12 hours,” and “Backed up offsite, kept 90 days,” plus reporting. That supports compliance work. It does not make a firm compliant. See the three NoDrama plans and what each covers.

Verify it

Read the finished plan against the upload path from end to end. Every system a client file touches, from the page to wherever it is stored, should appear in the Scope and have a named owner. If one step has no owner, the plan is not yet true of it.

Ask what your plan says about the upload page.

If the answer is nothing, NoDrama’s free WordPress audit is a place to start with the site it sits on.

Audit My Site

Common misreadings of the plan requirement

Signing W-12 means the plan is complete.

The form says “I am aware.”

The tax software vendor covers the website.

The vendor exemption does not reach a separately hosted website.

A third-party portal is handled.

The firm still oversees that provider under 314.4(f). If uploads run on the firm’s own site, the firm operates it.

A plan written once is done.

Pub 4557 says to “evaluate and adjust the program in light of relevant circumstances.”

What WordPress hardening covers lists the maintenance a plan can describe.

What this does not solve

This is not legal advice and not a plan review. It does not write the plan, designate the Qualified Individual, or decide whether the firm meets 16 CFR 314. It does not cover state-specific rules.

NoDrama maintains and secures WordPress sites. It does not set up MFA, encrypt uploads, or operate client portals, and none of those is a listed plan item.

The plan should be true of the upload page too

A data security plan for tax preparers is attested to every year and has to describe every system it claims to cover. If clients upload files through your own site, the plan should name that page, name who maintains it, and record how access, transit, monitoring and incidents are handled. No IRS text says so by name, so this is a reading of the scope language, and the call belongs to the firm and its Qualified Individual.

Frequently asked questions

No IRS text names the website. If client files reach the firm through it, our reading is that the plan should cover it.
In our reading of the scope language, yes: the page is a route for taxpayer information. How to name it is for the firm and its Qualified Individual.
Under 314.4(j), a notification event involving the information of at least 500 consumers must be reported to the FTC no later than 30 days after discovery. The rule defines it as "acquisition of unencrypted customer information without the authorization of the individual to which the information pertains."
Pub 5708 defines one as "any business service provider contracted with for services, such as janitorial services." Web and hosting providers are covered by implication only, so confirm with your Qualified Individual.
No. Line 11 of Form W-12 (Rev. 10-2025) says "I am aware," which attests awareness and is not a certificate that the plan is complete.
Written byPartha Biswas
Written byDeepti KarnHead of Business

Deepti leads business at NoDrama, which she founded in February 2026 after four and a half years at Pangolin Marketing. NoDrama came out of a question she kept running into: who is actually responsible for keeping a WordPress site fast, secure, accessible, and working? She writes about service design, ownership models, and what businesses should expect from whoever maintains their website.

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