Hint: Waiting Is the Riskiest Option

You may have heard the news: Thomson Reuters is retiring FileCabinet CS on Dec. 31, 2027. After that date, Thomson Reuters says it will no longer provide updates or support. You may still be able to view and export existing documents, but Thomson Reuters states it can’t guarantee continued access as operating systems, security, and authentication change. Its own recommendation is to move your data to another document management system before the deadline.

While that sounds like plenty of time, for a small firm it goes quickly. Take out the 2027 filing season, when no one wants to move their document system, and the fall extension crunch that follows. What’s left are two realistic windows: the rest of 2026, or the late spring and summer of 2027. Every firm still on FileCabinet CS is looking at the same two windows. This is just one example of the conundrum firms face when a vendor for a core software system announces that it is sunsetting the platform.

The Risks of Running a Software System Past the Sunset Date

In the case of FileCabinet CS, some owners may keep using it until after 2027, since the files may still open. That has risks because there will no longer be security fixes. Once updates stop, any weakness found in the software stays open. That’s the system holding years of returns, Social Security numbers, and bank information for every client. The result is a serious compliance gap.

Tax preparers are required under the Gramm-Leach-Bliley Act to maintain a written data security plan, and IRS Publication 4557 explains how to meet that obligation, including the Federal Trade Commission (FTC) Safeguards Rule. The IRS’s own checklist for safeguarding taxpayer data includes keeping software and security patches current. Knowingly storing client data on software that no longer receives patches is hard to square with that standard.

Cyber liability questions will also arise. If your firm carries cyber coverage, ask your carrier how it treats unsupported software, both at renewal and in the event of a claim. In addition, there will be no one to call once the sunset deadline passes.

This means that a corrupted database, a failed export, or a Windows update that breaks access is yours to solve. That could happen in the middle of busy season, and because everyone is facing the same deadline, timing is also a risk.

Every firm still on FileCabinet CS has the same end date and the same busy-season blackout. Moving a document archive takes time: files must be exported, checked, organized in the new system, and verified before anyone relies on them. Whether a firm hires help or does it in-house, that work takes time and attention. The firms that start late will be competing for the same limited help, in the same few months, with no room for a second attempt if something goes wrong.

The key takeaway is to decide on your transition window now. Even if the migration itself happens next summer, choosing the date and booking any outside help early keeps you out of the last-minute rush. Once you do, follow the steps below to migrate and mitigate the risks covered above:

Before choosing where your data goes, take an inventory of:

• How much data you have. Total size and number of client drawers drive the time and cost of any move.
• Active versus closed clients. Records past your retention period may not need to move into a new system at all. They can be exported and archived separately.
• Password-protected drawers. Many firms lock partner-only or sensitive clients behind drawer passwords.

Ask any provider whether drawer passwords carry over. If they don’t, sensitive client files could be open to your whole staff after the move. Whatever destination you choose, ask these questions of any vendor or consultant you are considering for your firm’s migration from FileCabinet CS or any other sunsetting software platform:

1. What is the all-in price, in writing? Ask what’s included: export, organization, verification, and support after the move.
2. Will my folder structure and client organization come across intact? Ask to see a sample of migrated files before committing your whole archive.
3. How are sensitive and duplicate drawers handled? Ask for a specific answer.
4. Can you show me an independent security audit? Your client data will pass through their hands. Ask for a System and Organization Controls (SOC) 2 report from the provider and from any subcontractors they use.
5. If this new system is ever retired, how do I get my files out? Make sure you can export your files if you ever need to switch again.

Run a small test first. Move a handful of clients, have staff work with those files for a week, and fix any problems before moving everything else.

Don’t Wait to Replace a Sunsetting Software System

The safest plan is to decide in 2026 when your firm will move, take inventory, and line up any outside help. The move itself can happen in the window that suits your practice, but the decision shouldn’t wait. Planning now allows your firm to choose the timing, test the move, and start the 2028 filing season on a supported system.