The FTC Safeguards Rule requires periodic risk assessments, which most compliance experts interpret as annually at minimum. However, accounting firms should conduct comprehensive IT security assessments in several situations:

·       Annually – to meet compliance requirements and identify new vulnerabilities

·       Before tax season – ideally October-December to ensure systems are ready for peak demand

·       After significant changes – new office locations, major software changes, mergers/acquisitions

·       After security incidents – to understand what happened and prevent recurrence

·       Before cyber insurance renewals – to document security posture for underwriters. Additionally, vulnerability scanning and security monitoring should happen continuously throughout the year.

Think of annual assessments as comprehensive physicals, while ongoing monitoring is daily health tracking. Both are necessary for proper security.