New York CPA commission and referral fee rules: what applies and how to disclose

New York CPAs are regulated by the State Education Department under the Education Law and the Rules of the Board of Regents, whose Part 29 defines unprofessional conduct with provisions for public accountancy. Read that current text, apply the AICPA commission rule if you are a member, and disclose any SourceX reward to the client in writing.

The short answer for New York CPAs

Start with the regulator's own rules. The State Education Department's Office of the Professions, advised by the State Board for Public Accountancy, regulates CPAs under the Education Law and the Rules of the Board of Regents. Part 29 of the Regents Rules defines unprofessional conduct and includes special provisions for public accountancy, which is where to look for commission and referral fee language.

For a SourceX reward, the practical answer has three parts: read the current Part 29 text, apply the AICPA commission rule if you are a member, and give the client a written disclosure before it applies. If your firm audits or reviews the company, expect the answer to be no until your counsel says otherwise.

Who regulates New York CPAs, and where is the text?

Source	Who issues it	What to look for
Education Law, Title VIII (the professions), including the public accountancy article	New York State Legislature	Definitions of public accountancy and who must be licensed
Rules of the Board of Regents, Part 29	Board of Regents	Unprofessional conduct generally, and the special provisions for public accountancy
Regulations of the Commissioner of Education	Commissioner of Education	Licensing and firm registration requirements
AICPA Code of Professional Conduct	AICPA, for its members	The commissions and referral fees rule
New York State Society of CPAs resources	Professional society	Commentary and member guidance; useful, but not the rule

Read the Regents Rules on the Office of the Professions website and date your notes. Society articles and CPE materials help with interpretation, but your license answers to the Education Law and the Rules.

What does the AICPA commission rule add?

For AICPA members, the Code adds a clear floor. Its Commissions and Referral Fees Rule, ET 1.520.001, sits next to the Contingent Fees Rule, ET 1.510.001 (AICPA Code, copy hosted by the Minnesota Board of Accountancy). Under 1.520, a member in public practice may not accept a commission for recommending a product or service to a client when the member or firm also audits or reviews that client's financial statements, performs certain compilations for it, or examines its prospective financial information. Where a commission or referral fee is permitted, it must be disclosed to the client. Quote the current wording from the AICPA's online Code rather than an older PDF.

When SourceX pays you because your client chose its service, you are in the territory the commission paragraph describes. Two consequences follow. Attest relationships are the first filter, and disclosure is the minimum wherever a payment is permitted. New York's text can be stricter, so the Code is the floor, not the ceiling.

If your firm also audits SEC registrants

Firms with public company audit clients run a second check. SEC auditor-independence rules on contingent fees form a separate regime from the AICPA Code, as SEC staff correspondence with the AICPA's ethics committee on contingent fees illustrates. SourceX works with private operating businesses, but if the company you want to introduce, or an affiliate, is connected to a registrant audit client, run it through your independence system before anyone mentions data licensing.

How does this apply in New York practice?

New York situation	Provisions to check	Answer to get first
Your firm audits a Long Island manufacturer that would qualify	AICPA 1.520 attest restriction and the Part 29 provisions	Treat as restricted; do not raise a reward
Client accounting services for a Manhattan professional services firm, with no reports issued	Part 29 text; written disclosure	Disclose in writing before the client applies
You are a CPA employed as a company's CFO, not in public practice	Whether the provisions reach you; your employer's conflict policy	Check both, and disclose any payment to your employer
A family-office client owns several operating companies	The services your firm provides each company	Assess each company separately
You are on the sell-side diligence team for a client's sale	Engagement confidentiality; the deal timetable	Coordinate with deal counsel and disclose to the board

The audit-client case gets its own treatment in our explainer on introducing audit clients.

A disclosure plan for New York clients

Timing. Deliver the disclosure before the client applies or signs anything, ideally in the same message that first mentions data licensing.
Format. A short letter or email the client acknowledges in writing.
Content. Name SourceX as the payer and state the basis in the program's own terms: 25% of eligible platform fees collected, with a $100,000 limit per referred company. A step-by-step illustrative commission calculation lets the client follow the formula with made-up inputs.
Trigger and source. Explain that a reward arises only after a closed deal and the buyer's payment, and that it is funded from SourceX's fee rather than the client's share.
Role. State that you make the introduction only and will not see, export or describe the company's records.
Sign-off. Have the engagement partner sign, copy the firm's ethics or risk partner, and file the acknowledgment with the engagement records.

Questions for the State Board or your counsel

How does the current Part 29 text handle compensation from an outside company that a client hires on your recommendation?
Which attest services rule a payment out, and are compilations for third-party use included?
Is written form required, and what has to be in the disclosure?
Is the analysis different when the payment goes to the firm?
Do New York's provisions reach licensees who are not in public practice?

How rewards are paid

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. Rewards are payable only after the buyer pays and SourceX receives its fee; no reward is guaranteed. Payment mechanics are spelled out in the program terms.

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

Next step

Before the client hears anything, put the company through the company fit checker, a preliminary and non-binding check. Once the disclosure is acknowledged, register as a partner. If the firm also serves West Coast companies, the California guide to commission disclosure is the natural comparison; the accountants hub lists the client profiles worth screening.

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

Common questions

Is New York State Society of CPAs guidance binding?

No. The Society is a professional association, and its articles and ethics resources are useful commentary. Your license answers to the Education Law, the Rules of the Board of Regents and the Commissioner's regulations, administered through the State Education Department. AICPA members also follow the AICPA Code as a condition of membership.

Does the AICPA commission rule apply if I work in industry rather than public practice?

The AICPA commission paragraph discussed here is written for members in public practice, so a CPA employed as a company's controller or CFO is in a different position. Your employer's conflict policy and any New York provisions that reach licensees outside public practice still matter. Check both, and disclose any referral payment to your employer.

What if the company I want to introduce is owned by an audit client?

Treat ownership links carefully. Independence and commission restrictions can extend to affiliates of an attest client, depending on the relationship and the rules that apply. Map the ownership structure, run your firm's independence check and get an answer from your ethics partner or counsel before mentioning a reward to anyone at the company.

When should the client receive my disclosure?

Before it applies to SourceX or signs anything, and ideally in the same message that first mentions data licensing. A disclosure that arrives after the client has acted looks like an afterthought. Keep a copy with the client's acknowledgment in the engagement file, and confirm the actual reward amount in writing if one is ever paid.

Does the client need to sign anything with me?

No agreement between you and the client is needed for the introduction itself. The client signs only its own agreement with SourceX, and only if it accepts the price and terms. A written acknowledgment of your disclosure is good practice and protects both sides, but it is not a contract and commits the client to nothing.

Free resources

Referral earnings calculator — Hypothetical partner earnings with the per-company cap.
Cash conversion cycle calculator — DIO, DSO, DPO and the cash conversion cycle.
Operational data inventory builder — List systems, record types, years held and owners.
All free tools · MCP resource center

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

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