Are you contesting the AI you use? Can you prove it?

Yet buried a little deeper in the Guidance Statement is an obligation that may prove far more challenging for firms to prove: the requirement to maintain genuine professional scepticism towards AI output, and to have documented processes that prove it.

Professional scepticism isn't optional

Paragraph 15 of TPB(GS) 55/2026 is unambiguous: 

"tax practitioners…should not rely on AI output as a substitute for their own analysis of a client's circumstances."

In other words, no matter how sophisticated your AI tools have become, or how reliable they have proven in the past, un-challenged acceptance of AI-generated advice, calculations or commentary is not compliant practice. Practitioners must be able to demonstrate their own professional judgement sits above, not beside, the machine.

This is a principle Ian Youngman, co-founder of Elfworks, has built into the platform's DNA from day one. 

"Accountants must be sceptical about AI output, no matter how long they've used it and how impressive its past performance has been," Youngman says. "The question firms need to ask isn't just 'is the AI usually right?' It's 'can I prove my staff actually understood, checked and challenged what the AI gave them, every single time?'"

Turning output into a test

This is where Elfworks' Create Learning feature comes in. With a single click, any AI-generated output on the platform can be converted into a structured Learning Module – effectively turning the AI's own work into a comprehension test for the human reviewing it.

"This means the firm now has a process of proving users have understood what the AI has produced, removing the risk of accounting firms relying on un-comprehended AI output," says Youngman.

This directly answers the requirement set out in paragraph 16 of the Guidance Statement: 

"Tax practitioners should verify and review AI generated content for accuracy throughout each step of the workflow and should establish processes to understand and contest AI decisions/outputs. Each of these steps should be documented."

Rather than relying on a staff member's memory that they "had a look" at the AI output, firms using Create Learning have a timestamped, structured record showing the specific learning outcomes tested, the questions asked, and the results achieved.

CPD as you work

There's an unexpected bonus baked into this compliance process, according to James McPhedran, co-founder of Elfworks.

"Every qualified accountant has a CPD obligation, be it a rolling 120 hours over three years or 40 hours per year, with the added complexity of minimum verifiable CPD, minimum yearly requirements and specialisation requirements," McPhedran explains.

"The Create Learning feature is such a neat solution. AI is being harnessed to help the human user review and challenge the AI output, and in the process, this helps the human user accumulate CPD credits. The Tax Practitioners Board requirements are being met and industry body CPD requirements are being satisfied, all through clicks of buttons, all stored in the Firm and user accounts on the Elfworks platform."

So what actually makes Create Learning "verifiable" CPD, rather than simply informal learning? According to McPhedran, it comes down to three elements: the existence of set learning outcomes, testing against those set learning outcomes, and a recorded completion of the Learning Module. Remarkably, AI takes its own output and serves it back to the user in this structured learning format in around 20 seconds.

The bottom line for Australian practices

TPB(GS) 55/2026 makes clear that AI adoption without a documented review process is no longer good enough. Firms need to show, not just tell, that their people are genuinely engaging with, questioning and understanding the AI tools doing work on their clients' behalf.

For practices searching for a way to meet this obligation without adding hours of administrative burden onto already-stretched staff, tools like Elfworks' Create Learning feature offer a practical answer – one that turns a compliance requirement into a genuine professional development opportunity, verified and documented at the click of a button.

With over 700 accounting practices now using Elfworks – including 15 of Australia's Top 50 firms – the platform is fast becoming the go-to local solution for firms grappling with both the productivity promise of AI and the compliance obligations that now come attached to it.

Visit elfworks.ai to see how the Create Learning feature can help your firm today.