If you started your own CPA firm in the last few years, or run a team of three to ten in San Francisco, New York, Washington, Boston or Seattle, you compete for staff accountants with employers that can outbid you on pay, brand and benefits. A seat can sit open through a busy season while the owner reconciles accounts at night. This article looks at white-label bookkeeping as a capacity layer for that kind of firm: what the BLS wage data say about your local market, what white-label does and does not mean under AICPA rules, which work to send first, and how to pilot it. It describes a well-documented capacity pressure, not a forecast that any firm will fail. For the national pipeline data, see our article on the US accountant shortage.
- BLS May 2025 data put the mean annual wage for accountants and auditors at $106,970 in Seattle, $108,660 in Boston and $113,640 in Washington. All-occupation mean hourly wages in all five metros named here sit 24% to 44% above the $33.54 US figure.
- BLS projects about 115,300 openings a year for accountants and auditors nationally. A small firm competes for those people in a tight local market.
- White-label means your firm keeps the client relationship and review. It does not remove the duty to tell clients that a third-party provider may be used (AICPA ET 1.150.040).
- Start with bookkeeping and month-end close. Tax-return support brings section 7216 and SSN-masking rules, so add it later and with advice.
- Pilot on three to five clients for three closes before you scale.
1. What the BLS data show for high-cost metros
The Bureau of Labor Statistics publishes metro-area wage data from its Occupational Employment and Wage Statistics survey. The table below uses the May 2025 estimates. Accountant-level figures appear in the BLS regional releases for three of the five metros, so those are shown. For New York and San Francisco, the releases we checked give only all-occupation figures.
| Metro area | Accountants and auditors employed | Mean annual wage, accountants and auditors | All-occupation mean hourly wage | Above US mean ($33.54) |
|---|---|---|---|---|
| San Francisco-Oakland-Fremont | Not in release | Not in release | $48.19 | 44% |
| New York-Newark-Jersey City | Not in release | Not in release | $41.50 | 24% |
| Washington-Arlington-Alexandria | 41,470 | $113,640 | $44.20 | 32% |
| Boston-Cambridge-Newton | 37,150 | $108,660 | $43.09 | 28% |
| Seattle-Tacoma-Bellevue | 22,100 | $106,970 | $44.13 | 32% |
Read these carefully. BLS calculates the annual figure by multiplying the hourly mean by 2,080 hours. The wages exclude benefits, payroll taxes and recruiting costs, and they describe an average across employers of every size, not what a small firm pays. They tell you how competitive the local market is, not what your firm would spend.
Nationally, the BLS Occupational Outlook Handbook projects 5% growth for accountants and auditors from 2025 to 2035, about 115,300 openings a year, and a 2025 median pay of $83,680. The same handbook projects a 6% decline for bookkeeping, accounting and auditing clerks over the decade, which BLS ties to automation, with about 144,100 openings a year still arising from turnover. For a small firm, the practical effect is fewer trained people entering the reconciliation and close layer while the work itself continues.
2. What white-label means, and what it does not
In practice, white-label means the offshore team works inside your QuickBooks Online or Xero file, follows your checklists and chart of accounts, and delivers close packs for your reviewer. The client deals with your firm, receives your reports and does not need a second relationship. It describes the commercial arrangement, not secrecy.
The AICPA Code sets the boundaries. The Journal of Accountancy's summary of the rules says ET 1.150.040 requires a firm to inform the client, preferably in writing, that a third party may be used on the engagement. This can sit in the engagement letter and should come before confidential information is shared. ET 1.700.040 treats a contractual agreement protecting confidential information, with other paragraph .02 conditions, as an option in lieu of client consent. The supervision and qualification duties for third-party work sit in ET 1.300.040. A well-run white-label arrangement is therefore one the client has been told about, with your firm remaining responsible for the work.
A second boundary is the line between bookkeeping and tax-return preparation. Where tax return information is involved, IRC section 7216 and Treasury Regulation 301.7216-3 apply. Under paragraph (b)(4), a US preparer may not obtain consent to disclose a Form 1040 filer's Social Security number to a preparer located outside the United States, and must mask the SSN first. A narrow exception depends on adequate data protection safeguards as defined by the Treasury. For that reason, many firms begin with bookkeeping and close, which carry less friction, and consider return support later with professional advice.
3. What to send offshore, and when
| Layer | Typical tasks | Offshore team | Your firm | Timing |
|---|---|---|---|---|
| 1. Bookkeeping | Bank and card reconciliations, coding to your rules, AP entry, AR application | Prepare to checklist, raise queries | Review exceptions, approve rule changes | Pilot |
| 2. Month-end close | Accruals, prepaids, fixed asset roll-forward, close pack, variance note | Prepare | Review and deliver to client | After two clean closes |
| 3. Compliance support | Sales tax workpapers, 1099 data preparation, payroll reconciliations | Prepare workpapers | Review, file and sign | Quarter two |
| 4. Tax-return support | Data entry, workpapers for Form 1040 or business returns | Only after advice on section 7216 and SSN masking | Preparer of record | Later, with advice |
| 5. Advice and client contact | Planning, advisory, signatures, attest | Not suitable | Always | Always |
4. Worked example: a five-person firm with 30 monthly clients
Facts (illustrative). A five-person firm in Boston has 30 monthly bookkeeping clients on QuickBooks Online. It estimates 5 hours per client per month for reconciliations, coding and close, or 150 hours. One staff seat has been open for four months, so the owner and one senior cover about 90 hours a month after hours. The owner wants to move preparation offshore for 8 clients first.
| Item | Calculation | Result |
|---|---|---|
| Monthly bookkeeping workload | 30 clients x 5 hours | 150 hours |
| Full-time seat equivalent | 2,080 hours / 12 months | About 173 hours a month |
| Seats of work in the book | 150 / 173 | About 0.87 of a seat |
| Pilot scope | 8 clients x 4 hours preparation | 32 hours a month offshore |
| Review kept in-house | 8 clients x 1 hour | 8 hours a month |
| Salary-only reference for 0.87 of a seat | 0.87 x $108,660 (BLS Boston mean, accountants and auditors) | About $94,500 a year before benefits, taxes and recruiting |
Reading the result. The BLS figure is a market reference for what a local seat costs on salary alone. It is not a comparison with any offshore fee, and this article does not state one. The planning point is that 150 hours is most of one full-time seat, and the pilot moves 32 of those hours while keeping 8 hours of review under the owner's control. If review points fall across three closes, the firm can add clients in steps. Hours vary by client, so treat these as sizing assumptions.
5. Controls before the first file moves
A well-run engagement should have these in place before live data is shared. Our control map for offshore data security covers each in detail.
| Control | Rule or source | What a firm should have |
|---|---|---|
| Client notice | AICPA ET 1.150.040 | Engagement letter wording that a third-party provider may be used |
| Confidentiality | AICPA ET 1.700.040 | Written agreement with the provider that protects client information |
| Provider oversight | 16 CFR 314.4(f) | Reasonable selection steps, safeguards required by contract, periodic assessment |
| Access and encryption | 16 CFR 314.4(c) | Multi-factor authentication and encryption in transit and at rest, or a documented equivalent control |
| Tax return information | IRC 7216; Treas. Reg. 301.7216-3 | Consent and SSN masking analysed before any return-related data is shared |
| Work quality | AICPA ET 1.300.040 | Competence check of the provider and supervision of its work |
Whichever provider you consider, ask to see the engagement terms, confidentiality agreement and security documents in writing before you decide, and do not rely on verbal assurances.
6. A 90-day pilot for a small firm
- Days 1 to 15. Update the engagement letter, sign the confidentiality terms, add the provider to your written information security plan and set up named logins with multi-factor authentication.
- Days 16 to 30. Choose three to five clients with clean records. Hand over the chart of accounts notes, bank rules and a written close checklist for each.
- Days 31 to 90. Run three monthly closes. Log review points by type and reviewer minutes per client.
- Day 90. Decide to expand, adjust the procedures or stop. Expand only if review points fall.
7. Checklist
- You have sized the gap in hours by client and task, and named the reviewer with protected time.
- The engagement letter tells clients a third-party service provider may be used.
- A written confidentiality agreement is signed before any client data moves.
- Your information security plan covers the provider, with named-user MFA and encryption.
- Tax return data and SSNs are excluded from the pilot.
- Success measures are agreed: review points per close, turnaround days and reviewer minutes per client.
8. Frequently asked questions
What does white-label bookkeeping mean for a CPA firm?
The offshore team works inside your accounting software, to your checklists and under your review, and the client deals only with your firm. White-label describes the client relationship, not secrecy about who touches the data. The AICPA interpretation on third-party service providers expects the firm to tell the client, preferably in writing, that a third party may be used.
Do we have to tell clients that an offshore team is involved?
Under AICPA ET 1.150.040 the firm should inform the client, preferably in writing, that a third-party service provider may be used on the engagement, and this can sit in the engagement letter. Where tax return information is involved, a separate consent under IRC section 7216 may also be needed.
Why are high-cost metros affected differently?
BLS data for May 2025 show metro wage levels well above the national all-occupation mean hourly wage of $33.54, for example $48.19 in San Francisco, $44.20 in Washington and $43.09 in Boston. A small firm competes for staff accountants against larger employers in the same labor market, so seats can be slow to fill and costly to carry.
Which work should a small firm send offshore first?
Start with bank and credit card reconciliations, transaction coding to your rules, accounts payable entry, accounts receivable application and month-end close checklists for monthly bookkeeping clients. These can be checked by a reviewer against source documents and do not involve tax return preparation.
Can SSNs be sent to an offshore team for tax return work?
Not by simple consent. Treasury Regulation 301.7216-3(b)(4) says a US preparer may not obtain consent to disclose a Form 1040 taxpayer's Social Security number to a preparer located outside the United States, and must mask the SSN, with a narrow exception for adequate data protection safeguards defined by the Treasury. Many firms therefore start with bookkeeping and close work and take tax-return support later with advice.
What do the FTC Safeguards Rule requirements add?
Where your firm is covered, 16 CFR 314.4(f) requires you to select service providers capable of maintaining appropriate safeguards, require those safeguards by contract, and periodically assess the providers. The rule also calls for multi-factor authentication and encryption of customer information in transit and at rest, unless an approved equivalent control is documented.
How should a small firm run a pilot?
Pick three to five clients with clean records, run three monthly closes, and log review points by type and reviewer minutes per client. Expand only if review points fall. A pilot of about 90 days gives enough closes to see whether the written procedures are working.
Will white-label bookkeeping certainly solve our staffing problem?
No. Results depend on the quality of client records, reviewer time, written procedures and software set-up. The figures in this article describe local labor market conditions and do not predict the position of any individual firm.
9. Sources
- BLS, Occupational Employment and Wages in Washington-Arlington-Alexandria, May 2025 (accountants and auditors employment and wages): bls.gov
- BLS, Occupational Employment and Wages in Boston-Cambridge-Newton, May 2025: bls.gov
- BLS, Occupational Employment and Wages in Seattle-Tacoma-Bellevue, May 2025: bls.gov
- BLS, Occupational Employment and Wages in San Francisco-Oakland-Fremont, May 2025 (all-occupation mean hourly wage $48.19; US $33.54): bls.gov
- BLS, Occupational Employment and Wages in New York-Newark-Jersey City, May 2025 (all-occupation mean hourly wage $41.50): bls.gov
- BLS, Occupational Outlook Handbook, Accountants and Auditors (median pay, projection, openings): bls.gov
- BLS, Occupational Outlook Handbook, Bookkeeping, Accounting, and Auditing Clerks: bls.gov
- eCFR, 26 CFR 301.7216-3, Consent to use or disclosure of tax return information: ecfr.gov
- eCFR, 16 CFR 314.4, Elements of the information security program: ecfr.gov
- Journal of Accountancy, "Working with third-party experts", Nov 2022 (AICPA ET 1.150.040, 1.700.040, 1.300.040): journalofaccountancy.com; AICPA Code of Professional Conduct: pub.aicpa.org
Somesh Chandak & Associates, Chartered Accountants (FRN 158694W), Thane, supports accounting firms abroad with bookkeeping, reconciliations and month-end close on QuickBooks Online and Xero, working under your review and your brand. We can walk through scope, workflow and the documents your firm will need before any client data moves.
Outsourced Bookkeeping for Foreign Firms Talk to usThis article is for general information for accounting professionals and is not legal, tax or data-protection advice. Wage figures are BLS May 2025 estimates and describe local labor markets, not any firm's cost. Confirm your own position with counsel and your tax adviser before sharing client data with any third party.