Digital Nomad
IRS AI Governance Policy: What Digital Nomads & Remote Workers Should Know
The IRS's Aug 2026 AI governance policy doesn’t just apply internally—it has implications for privacy, recordkeeping, and use of generative AI tools by anyone dealing with IRS systems or data.
By NomadicTax Research Team • 5-8 min read • September 5, 2026
## What’s in the New AI Governance Policy?
On **August 10, 2026**, the IRS issued an updated Internal Revenue Manual policy, **IRM 10.24.1**, titled *“IRS Policy for Artificial Intelligence (AI) Governance.”* It sets requirements for how the IRS uses AI—especially generative AI—and how contractors and vendors engaging with the IRS must comply. ([irs.gov](https://www.irs.gov/irm/part10/irm_10-024-001r?utm_source=openai))
Key components include:
- The revision of section 10.24.1.8: Instead of long guidelines, the policy now refers to **IRM 1.15.6, Managing Electronic Records**, for managing records and data. ([irs.gov](https://www.irs.gov/irm/part10/irm_10-024-001r?utm_source=openai))
- Establishing **use case inventories**—all AI tools used by or for the IRS must be cataloged (including contractors/vendors). ([irs.gov](https://www.irs.gov/irm/part10/irm_10-024-001r?utm_source=openai))
- Clear rules for **generative AI**: definitions, approved software, prohibited uses, oversight and certification of high-impact AI systems. ([irs.gov](https://www.irs.gov/irm/part10/irm_10-024-001r?utm_source=openai))
## Why Digital Nomads Should Care
If you're a digital nomad, remote worker, or consultant who utilizes AI tools, this policy matters if you're interacting with, contracting with, or transmitting data to the IRS or related systems.
- **Data Privacy & Security**: Policies demand protection of privacy, civil rights, and strong data management. If you're handling taxpayer data—even your own—know that consent, proper storage, and secure tools are essential.
- **Vendor Certifications**: If you use third-party tools, some must be “IRS- or Treasury-approved” for generative AI tasks. Unsanctioned tools could put you at risk if they are used in contexts governed by the IRS policy.
- **Recordkeeping**: Under IRM 1.15.6 referenced in the policy, records of AI system use, training data, provenance, and decision logs may be required. Losing track could lead to compliance risks.
## Examples & Scenarios
- A nomad using ChatGPT or similar AI to help prepare US tax filings should check whether the tool meets IRS or Treasury approvals and properly maintains logs of input/output if used for official tasks.
- Consultants offering AI-enhanced services to US-based clients must ensure their contracts allow for compliance with these IRS policies when IRS-facing work is involved.
## Action Steps to Stay Ahead
- If you’re working with AI tools and interacting with IRS data, document **which tools**, **how (what tasks)**, **data sources**, and whether those tools are IRS/Treasury-approved.
- Review your agreements with clients about data protection and record retention.
- Stay abreast of **Treasury and OMB guidance**, especially if your tools involve cross-border data or remote access.
This policy shows the IRS catching up with rapidly advancing technology—contractors, remote workers, and digital nomads need to understand how their tools and behaviors intersect with these evolving governance requirements.