ICF Code of Ethics and referral fees: what coaches should disclose, and when

The ICF Code of Ethics treats referral fees as a disclosure and conflict-of-interest matter: coaches are expected to tell clients and sponsors about compensation they may receive from third parties for referrals and to manage any conflict openly. Before introducing a client to SourceX, disclose the possible reward in writing and leave the decision with the client.

The short answer: disclose the reward, manage the conflict, keep the client in charge

Whether and how a coach may accept a referral fee depends on three things: whether you are bound by the ICF Code of Ethics as a member or credential holder, whether the person you would introduce is a current client or sponsor, and what your coaching agreement says. As we read the published Code, it handles referral compensation through disclosure and conflict management, so the practical answer is a written disclosure before the introduction and a genuinely free choice for the client.

In practice that means one short paragraph, in writing, before you make any SourceX introduction: what you could receive, who pays it, and that the coaching continues unchanged whatever the client decides. If you also recommend SourceX in public, federal guidance on endorsements comes into play as well.

What the ICF Code of Ethics says about conflicts and third-party compensation

The ICF Code of Ethics applies to ICF members and ICF credential holders, and it is revised from time to time. Read the current version on the International Coaching Federation's website before relying on any summary, including this one; the exact wording governs. Two themes matter for referral fees.

  • Conflicts of interest. The Code expects coaches to be aware of actual or potential conflicts of interest, to disclose them openly and to work through them with the people affected.
  • Compensation from third parties. The Code expects coaches to disclose to clients and sponsors compensation they may receive from third parties for referrals.

The Code also distinguishes the client, the person being coached, from the sponsor, the organization or person paying for the coaching. That distinction drives most of the situations below, because a reward connected to a sponsor's business may need to be disclosed to both.

The second source in play is the Federal Trade Commission. The FTC's Endorsement Guides at 16 CFR Part 255, including section 255.5 on disclosure of material connections, are the FTC's interpretation of Section 5 of the FTC Act rather than binding rules in themselves. They matter when a coach recommends SourceX in a newsletter, a podcast or a LinkedIn post while able to earn a referral reward: that connection should be disclosed clearly.

Tax is the third. Referral payments are generally taxable income to the person who receives them, as the IRS explains for income in general in Publication 525, and US partners are typically asked for a Form W-9 so payments can be reported. Confirm your own position with a tax adviser.

How the rules apply in common coaching situations

SituationWhat to checkOutcome to confirm
You coach an owner-CEO who pays you directlyYour coaching agreement and the Code's disclosure expectationThe client has a written disclosure and chose to be introduced
You coach an executive under a contract with their employerWho the sponsor is, the sponsor's vendor and conflict policies, and whether the executive could authorize a license at allDisclosure to both client and sponsor, or no introduction
The engagement ended last yearContinuing confidentiality terms in the old agreementYou use only what the former client chooses to share now
You run a group program or mastermindThe group agreement and the room's confidentialityIntroductions happen one-to-one, never during a session
You mention SourceX in a newsletter or postWhether your audience would expect you to be paidA clear statement near the recommendation that you may earn a referral reward
You also hold a CPA license, a law license or a securities registrationThat profession's own referral-fee and outside-activity rulesThose rules are satisfied first; they can be stricter than the Code

Coaches who also hold securities registrations should read the guide to outside business activity rules for registered reps. Coaches who are also attorneys can use the ethics checklist for lawyers recommending a vendor. Group coaches and peer-group chairs will find room-specific norms in the guide to peer group member introductions.

Disclosure and consent good practice

Disclosure works when it is early, written and specific. A coach who mentions a reward after the client has already applied has disclosed too late.

  • Separate the introduction from the coaching. Raise it outside session time, or at the end of a session with the client's agreement, and never frame it as a coaching goal.
  • Put the disclosure in writing before the introduction: what you could receive, who pays it and when it would be paid.
  • Say that SourceX pays the reward out of its own fee, so it never reduces what the client's company receives.
  • Tell the client the coaching continues exactly as before whatever they decide.
  • Keep a dated copy of the disclosure and the client's reply with your engagement records.

A disclosure a coach can adapt for an owner-client:

For a sponsor-funded engagement, add a line to the sponsor's HR or procurement contact:

Questions to settle before you accept any referral compensation

  1. Am I bound by the ICF Code as a member, a credential holder or both, and have I read the current version?
  2. Who is my client and who is my sponsor in this engagement, and have I told both?
  3. Does my coaching agreement say anything about outside relationships or third-party compensation?
  4. Could the reward influence, or appear to influence, my coaching? If so, would declining the reward or skipping the introduction be wiser?
  5. Do other licenses or registrations I hold impose stricter rules?
  6. How will I report the income, and what will my tax adviser need from me?
  7. Does my professional liability policy respond to a claim arising from a referral? The guide on liability and E&O cover for referrals lists questions for your broker.

This is general information, not legal, tax or financial advice. Confirm with your own counsel, tax adviser or professional body before acting.

What happens after a coach makes an introduction

Your role is the introduction and a few lines of fit information. The client's company works directly with SourceX from there, and you never handle, export or describe its records.

  1. You share your referral link, which opens sourcex.si/apply with your code attached, or you submit the company through the referral form with the client's agreement.
  2. SourceX confirms the basics with the company's sponsor: a US company with 50+ full-time employees at peak (contractors excluded), several years of documented operations, the right to license its records and a decision-maker who can sign. The who qualifies page has the details.
  3. The company inventories its systems and the history each one holds.
  4. Price and terms are agreed before any buyer reviews the opportunity, and nothing binds the company until it signs.
  5. After the deal closes and the buyer pays, SourceX pays the referral reward.

Partners earn 25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, capped at $100,000 per referred company, payable only after the buyer pays and SourceX receives its fee. No reward is guaranteed.

Next step

Use the network opportunity finder to list which clients and contacts might fit, and draft your disclosure before you speak to any of them. When you are ready, register as a partner. For a wider view of how coaches use the program, read the referral program overview for business coaches.

  1. Step 1Share your linkSend your personal link to a company you know.
  2. Step 2Company appliesThe company applies itself at /apply.
  3. Step 3Buyer selects and paysThe buyer selects and pays for the data and SourceX receives its fee.
  4. Step 4You get your rewardYour share of SourceX fees becomes payable.

Common questions

Does the ICF Code of Ethics prohibit coaches from accepting referral fees?

As published, the Code approaches referral compensation through disclosure and conflict management rather than an outright ban: coaches are expected to disclose to clients and sponsors compensation they may receive from third parties for referrals. Read the current text yourself, because the Code is revised periodically, and check any stricter rules from other licenses you hold. This is general information, not legal advice.

Do I need to disclose a referral reward to someone who is not my coaching client?

The Code's disclosure expectation centers on clients and sponsors, but disclosure is still sound practice with anyone you introduce. People weigh a recommendation differently when the person making it could be paid. If you recommend SourceX publicly, the FTC's endorsement guidance expects a material connection such as a referral reward to be disclosed clearly, close to the recommendation.

Is a verbal disclosure enough, or should it be in writing?

Put it in writing. A short email or message before the introduction creates a record of what you said, when, and how the client responded. It also gives the client time to think rather than reacting on the spot. Keep a dated copy with your engagement records, and repeat the disclosure if the client later involves colleagues or the sponsor.

What if my client is an executive whose employer pays for the coaching?

Then the employer is the sponsor and both client and sponsor should hear about any reward. Check the sponsor's vendor and conflict policies first. The executive may also lack authority to approve a data license, which belongs with the owner, CEO, CFO or another authorized representative. Often the cleaner path is to tell the client the option exists and let them raise it internally.

Can a coach help a client prepare the data inventory?

A coach can encourage the client to complete it and help them think about who inside the company should own it, but should not handle, export or describe the company's confidential records. The company completes its inventory directly with SourceX, and de-identification and redaction requirements are agreed with the company before any work on the data begins.

Free resources

By SourceX Partnerships Team · Published 2026-10-09 · Updated 2026-10-09

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