# Ask your CPA to add your records to the annual review

> Ask your CPA or fractional CFO for one records page in your annual review and one clause in your AI policy. Four questions, one data map, one next step.

By Matt Burns, Vaultfish. Canonical: https://vaultfish.com/partners/cpas-and-cfos/the-data-line-item  
Published: 2026-08-27  
Updated: 2026-10-14

If your CPA or fractional CFO runs an annual review with you, ask them to add one page about your records. If they help with your AI policy, ask for one clause too. Neither needs a new service.

## What question is missing?

Can your company license its own records, and on what terms? Few AI policies say. Most cover which AI tools staff may use and say nothing about what the company owns.

> **Every AI policy has to answer a plain question.** The policy covers the downstairs. The attic is open.

A license rents out the records for a while, under rules. Your company keeps the house. Get that idea in writing before someone else suggests it.

## A page in the annual review

Ask your CPA to add a one-page section called "Records and AI." Four questions fill it.

Our [company data map](/tools/data-map) answers the first three in one sitting. It makes a one-page inventory you can hand to your CPA and file.

1. **What systems hold records?** Slack, email, CRM, tickets, code, wiki.
2. **How many years do they cover?** First message to today.
3. **Who holds the admin login?** And does the login still work?
4. **What limits sharing?** Customer contracts, vendor terms, employee notices.

Begin with your SaaS expense list. Chat, ticketing and CRM tools show up there as line items, and your CPA already has that list.

## A clause in your AI policy

Our [AI policy generator](/tools/ai-policy-generator) includes a section on company data licensing. The clause answers three things.

- **Who may approve a license?** Name a role, such as the CEO with counsel.
- **What is off limits?** Customer secrets, employee personal data, privileged files.
- **How is a buyer checked?** Ask about who the buyer is and how they handle records.

**An AI policy with and without a data clause**

|  | No data clause | Short data clause |
|---|---|---|
| Names who approves a license |  | Yes |
| Lists what is off limits |  | Yes |
| Says how a buyer is checked |  | Yes |
| Pick this when | Nobody has asked about the records yet. | Someone will, and you want the answer in writing. |

## Keep the data on its own line

If your CPA or CFO values the company, ask them to keep any data asset on a separate line from enterprise value. Our [EBITDA multiples tool](/tools/ebitda-multiples-by-industry) has an optional data asset line for this.

A license is its own stream. It may come from a different buyer on different terms.

Any figure on that line should carry its source. Public deals show a range. Small shutdowns sold archives for $10,000 to $100,000 each, per [Gizmodo](https://gizmodo.com/failed-companies-are-selling-old-slack-chats-and-email-archives-to-train-ai-2000747916).

Google won the auction for one airline's archive with a $10 million bid, and court approval is pending, per [Time](https://time.com/article/2026/08/25/google-spirit-airlines-ai-data-RL/).

**$10K to $100K** What small shutdowns have sold their archives for ([source](https://gizmodo.com/failed-companies-are-selling-old-slack-chats-and-email-archives-to-train-ai-2000747916))

  

**$10M** Google's winning bid for one airline's archive. ([source](https://time.com/article/2026/08/25/google-spirit-airlines-ai-data-RL/))

How any proceeds are booked and taxed is your CPA's call. We do not give tax advice.

## What happens after the review page?

One of three things.

1. **File it** The records look thin. You file the page. Fine.
2. **Run the check** You want a quick result.
3. **Talk to Matt** You want help with a buyer.

You can run the free [data check](/business) on your own. It takes about three minutes. If the result looks worth a call, [send Matt a note](/contact), or read the [buyer comparison](/buyers) first.

## How it reads in the engagement letter

Here is a sample line your CPA can adapt for the review letter.

> "We reviewed what records the company holds, how long they go back, and what limits sharing. We noted that some AI labs license company records, and set a policy clause on who may approve a license."

That is the whole addition. It fits inside the review you already have.

## How long does it take?

Most of the work is yours. You list systems and years. Your CPA reviews them, asks the four questions, and files the page.

_Glim bills nothing. Glim cannot find the invoice button._

## Questions owners ask

### Does an AI policy data clause commit my company to a license?

No. A data clause names who may approve a license and what is off limits. Your company still decides on every license request.

### What if my company has no AI policy yet?

Start with the free Vaultfish AI policy generator. It produces a draft your lawyer can edit, with a data licensing clause included.

### My CPA's firm does our audit. Can they still add the records page?

Yes. A Records and AI page in the annual review is plain advisory work. Before suggesting any referral, an auditing CPA checks with their independence lead.

### Is the Vaultfish data map public?

No. The data map stays in your own files, and nothing goes to a buyer without your yes.

_Vaultfish helps you run the process. We are not lawyers and this is not legal advice. If you need counsel who knows this area, we can point you to one._