Chief financial officers should ask their valuation firm in writing how it uses AI to value businesses and assets for the financial statements. A new draft framework says the firm's work file, the papers that back up a value, should show that use. The firm's valuation professional stays responsible for the value, whatever tools were used.
On October 8, 2026, the American Institute of Certified Public Accountants (AICPA) asked for comments on a draft called the Valuation Performance Framework. The AICPA released it with the American Society of Appraisers and the Royal Institution of Chartered Surveyors. Comments are due by December 22, 2026. The three bodies say they will not publish the comments.
The draft guides professionals who estimate fair value, one kind of value a company reports in its financial statements. It covers values of businesses and of some assets and liabilities, for public and private companies. It sets the least work and the least documentation each value needs. An experienced professional who was not on the job should be able to follow the work file.
The draft revises a framework issued in January 2017. That earlier framework was mandatory only for holders of one valuation credential. The credential was discontinued in 2023. According to the draft, professionals without the credential also adopted the 2017 framework for US financial reporting.
The draft adds a new section on AI and other technology tools. It lists uses being explored in practice, such as research, data gathering, analysis and report writing. It says the valuation professional "is ultimately responsible for the valuation conclusion" and cannot hand any part of that responsibility to the tools. The professional should also understand the limits of the tools used.
Checks on AI output should match how much the value relies on that output and how much it moves the value. They can range from a test of whether a result looks reasonable to verifying the result. The work file should let an experienced professional who was not on the job see how far AI tools were used. It should also show the checks and judgment behind relying on their data and results.
The engagement letter is the contract that hires the valuation firm. Disclosure of AI use in that letter and in the final report should follow five things. They are regulators' rules, professional guidance, industry practice, the client's contract terms and the firm's policies. AI use should also respect the contract's confidentiality terms for client data. The draft calls disclosure of AI use "an evolving area".
All the draft's principles apply to valuation staff employed inside a company. Such a staff member may not need a signed engagement letter. The draft says that person should still record the basic terms of each assignment.
Nine-67's view is that the next engagement letter for fair value work should name the tasks AI tools may do. The letter should also say where client data may go and what the work file will record about AI. The company's cost is its finance team's time to agree those terms and read the file. Any extra checking by the valuation firm should be priced in that letter. The draft also says documentation should generally grow when the technology is harder to see into.
What to do first:
- Chief financial officer: before signing the next engagement letter for fair value work, ask the valuation firm which tasks AI tools do.
- Controller: add terms to that letter on where client data may go and what the work file records about AI use.
- Head of any in-house valuation team: record the basic terms of each assignment, including any AI tools used.
- Chief financial officer: decide by December 22, 2026, whether to send the company's comments on the draft.
