What Does the German Chamber of Tax Advisors Say About AI? The FAQ in 12 Points

The German Federal Chamber of Tax Advisors (BStBK) revised its FAQ on AI in the profession on 27 October 2026. The document runs to 38 pages and reflects the law as of September 2026. This article puts the statements that matter most in daily practice into context. It does not replace reading the original.

What does the BStBK FAQ cover?

In nine chapters, the FAQ answers practical questions on using AI: from skills and cost to tool selection and professional law, through to quality assurance, documentation and client communication. Its baseline is clear: AI complements expertise, and responsibility stays with people.

What are the twelve key statements?

1. No duty to use AI. Using AI is voluntary. The chamber still advises engaging with it, partly because of the skills shortage.
2. AI literacy is a deployer duty. The FAQ speaks of sufficient staff competence. Since 27 July 2026, Art. 4 of the AI Act requires measures that support the development of AI literacy. Anyone using AI on their own responsibility in a firm is generally a deployer under the regulation.
3. Responsibility stays with the professional. A qualified person must check and approve every result. The BStBK compares AI output to the work of inexperienced staff.
4. Public AI services are no place for client data. Without contractual safeguards, no personal or engagement-related content may go there. Without safeguards, the rule is to anonymise or pseudonymise.
5. § 62a StBerG also applies to AI vendors. Vendors must be bound to secrecy before they gain knowledge of client data. The contract must be in text form.
6. Private AI accounts are off-limits. The FAQ treats professional use of private AI as impermissible. Firms should provide business accounts.
7. EU vendors are preferable. The chamber recommends European vendors or data centres in the EU. That makes GDPR compliance and secrecy easier.
8. Dictation AI is permitted in principle. That includes file memos, conversation notes and transcription. The precondition is prior consent from everyone involved under § 201 StGB. The chamber considers offline use preferable.
9. The GDPR applies in full. Firms need a legal basis, a data processing agreement, technical safeguards and deletion concepts. High-risk use adds a data protection impact assessment.
10. Rules and an overview belong in place. The FAQ recommends an AI policy, an approval process for new tools and an AI inventory. No form is prescribed, and a lean table is often enough.
11. Informing clients is graduated. There is currently no express professional duty to disclose. Data protection law does require information once personal client data flows to an AI service.
12. Internal notes need no label. For purely internal use there is generally no labelling duty under Art. 50(4) of the AI Act. Later publication calls for a new check.

What does this mean for AI meeting assistants?

The FAQ names transcription of conversations explicitly. For firms that leaves four checks: Has everyone involved consented in advance? Is the vendor bound under § 62a StBerG? Is there a data processing agreement? Where is the data processed? The article May an AI tool transcribe client meetings? goes into detail.

TaxMeet (Next Intelligence GmbH, Berlin) captures conversations without a meeting bot, directly on the device, and stores transcripts and documents in Frankfurt am Main. That doesn't replace consent: the firm obtains it itself before every conversation. We provide template wording for this.

What should firms do now?

The easiest start is an inventory: which AI tools does the team already use, including unofficially? That produces the AI inventory and a first policy. Every tool that touches client data then goes through the vendor check.