What Ohio CPAs should check before accepting a commission, referral or contingent fee

Ohio CPAs should test a referral reward against three layers before accepting it: the Accountancy Board of Ohio's statute and rules, the AICPA's commission and contingent fee rules for members, and SEC independence rules where the firm audits public companies. Because the reward depends on a deal closing, it raises commission and contingent fee questions.

The short answer for Ohio CPAs

An Ohio CPA should check three layers before accepting a referral reward: Ohio's accountancy statute and the Accountancy Board of Ohio's rules, the AICPA Code's commission and contingent fee rules if you are a member, and SEC independence rules if your firm audits a public company connected to the client. A SourceX reward is paid only when a licensing deal closes and the buyer pays, which is why Ohio practitioners ask about contingent fees as well as commissions.

This guide shows where each layer lives, how the two AICPA rules interact and how to build a disclosure file. It does not reproduce Ohio's rule text, so read the board's current rules before relying on any conclusion.

Why a deal-dependent reward raises two questions

The AICPA Code treats commissions and contingent fees in separate rules, and a reward that depends on an outcome can look like either.

Contingent fees. Under the AICPA Code, a contingent fee is one whose amount depends on attaining a specific finding or result, and members may not perform services for a contingent fee for a client whose financial statements the firm audits or reviews, for whom it issues certain compilations, or whose prospective financial information it examines, as the NYSSCPA's article on when a contingent fee arrangement is an act discreditable explains.
Commissions and referral fees. The commission rule covers payments a member receives for steering a client toward someone else's product or service, with a similar list of attest relationships that bar it and a disclosure requirement where it is allowed.

Which rule governs depends on classification: SourceX, not the client, pays the reward, and the CPA performs no service for SourceX's buyers. Settle the label with your ethics counsel before you rely on either rule.

States can also go further than the AICPA. The New Jersey Society of CPAs' overview of commissions and contingent fees shows a state whose rules differ from the Code, for example by barring a contingent fee for preparing an original or amended tax return. Read Ohio's text with that possibility in mind.

Where Ohio's rules live

Layer	Who sets or enforces it	What to look for
Chapter 4701 of the Ohio Revised Code	The General Assembly; enforced by the Accountancy Board of Ohio	Any provision on commissions, contingent fees, referral fees or acts discreditable, and who counts as practising public accounting
The board's rules in the Ohio Administrative Code	Accountancy Board of Ohio	Professional standards, whether AICPA standards are adopted by reference, disclosure requirements
AICPA Code of Professional Conduct	AICPA, for members	ET 1.520 on commissions and referral fees, ET 1.510 on contingent fees
SEC auditor independence rules	SEC, for audits of SEC registrants	Contingent fee and other independence limits that apply alongside the AICPA Code
Firm policy	Your firm	Client acceptance, independence and outside-income rules, which can be stricter than all of the above

The Ohio Society of CPAs offers ethics resources to members, but it is a professional association, and the board's rules are the ones that carry weight for your license.

The SEC overlay for firms with public-company clients

Most companies worth introducing to SourceX are private operating businesses, so the SEC layer often falls away. It matters when the company is a subsidiary of, or otherwise connected to, an SEC registrant that your firm audits. SEC staff correspondence with the AICPA ethics committee, such as the Office of the Chief Accountant's 2004 letter on contingent fees, reflects that SEC independence rules form a separate regime from the AICPA Code. Firms with registrant audit clients should run the question past their independence team as well as their ethics counsel.

The double-trigger screen

Run each company through both rules, then the SEC overlay. A yes in any column means stop and confirm before going further.

Client situation	Commission rule bars it?	Contingent fee rule bars it?	SEC overlay?	Direction to confirm
Firm audits or reviews the company	Yes under the AICPA Code	Yes, if the reward is classed as a contingent fee	Only if a registrant is involved	Make the introduction reward-free, or skip it
Firm compiles statements a lender relies on	Possibly; read the exact compilation wording	Possibly	Rarely	Ask counsel before saying anything about a reward
Firm prepares tax returns only	Not on the AICPA attest list	Check any state tax-return limits	No	Written disclosure route, checked against Ohio's text
Firm provides advisory or outsourced accounting only	No attest bar under the AICPA Code	No attest bar under the AICPA Code	No	Written disclosure route
Company is a subsidiary of a registrant the firm audits	Check	Check	Yes	Independence team first
Company is a contact, not a client	Likely outside client-based limits	Likely outside	No	Disclose anyway as good practice

Build the disclosure file in six steps

Record the screen. Save the double-trigger table for this company, dated, with the name of whoever checked the firm-wide client list.
Record the rules. Note the Revised Code sections and board rules you read, the AICPA paragraphs relied on and the date.
Write the disclosure. Explain that SourceX pays the reward from its own fee, how it is calculated, that it is payable only after the buyer pays and SourceX receives its fee, and that the client's price is unaffected.
Get it acknowledged before the introduction, and keep the acknowledgment with the engagement letter.
Decide the payment's destination. Keep, decline or pass it through; the page on whether to pass a referral fee through to your client weighs the options.
Revisit when services change. If the client later engages the firm for a review or audit, redo the screen before the engagement starts, because the answer can flip.

What to say in the client meeting

Raise it out loud first, then follow up in writing.

How the reward is calculated and when it is 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 become payable only after the buyer pays and SourceX receives its fee, and no reward is guaranteed. For a plain-language walkthrough of the formula that avoids quoting any figure, use the guide on calculating an illustrative referral commission from a platform fee.

Once you have introduced the company, SourceX qualifies it, the company builds an inventory of its systems and records, the company agrees price and terms, buyers review, and the company is paid when the deal closes and data is delivered; the partner reward comes last. The companies worth that effort are US businesses with 50+ full-time employees at peak (contractors excluded), years of documented operations spread across many systems, the right to license those records and an owner, CEO, CFO or other authorized sponsor.

Questions for the Accountancy Board of Ohio or your counsel

How would the board label a reward paid by a data licensing platform: commission, contingent fee, referral fee or none of these?
Do the board's rules adopt the AICPA's attest-client limits as written, or add to them?
Is there a tax-return or other service-specific limit that the AICPA Code does not have?
Must the disclosure be written, and must it precede the recommendation?
How long before an attest engagement begins does the restriction apply?

For other states, compare the guides to Illinois CPA commission rules and Pennsylvania CPA referral fee rules.

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

Next step

Check the company with the company fit checker, read the program terms, and when the file is complete, register as a partner. The page on referral opportunities for accountants suggests which clients in an Ohio book to screen first.

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

Does Ohio follow the AICPA contingent fee rule word for word?

Do not assume it does. States can adopt the AICPA provisions, write their own or combine both, and some add limits the Code lacks, such as a ban on contingent fees for preparing tax returns. Read Chapter 4701 of the Revised Code and the Accountancy Board of Ohio's current rules, and note the exact sections you relied on in the client file.

Can an Ohio CPA accept a referral reward from a tax-only client?

Under the AICPA Code, tax preparation alone is not one of the attest services that bar a commission, so the usual route is written disclosure. Ohio's text may treat tax work differently, and the reward is not a fee for preparing a return, so confirm both points with your counsel. If the firm later adds a review or audit, redo the analysis.

Does the SEC independence overlay apply to a private company?

Usually not on its own, because SEC independence rules attach to audits of SEC registrants. The overlay matters when the private company is owned by, or otherwise connected to, a registrant your firm audits. Ask your independence team to check the relationship before you mention any reward, since their answer can override an otherwise permitted commission.

What if the client asks the firm for a review after the introduction?

Redo the screen before accepting the review engagement. A commission or contingent arrangement that was acceptable for an advisory-only client can become barred once the firm performs attest work, depending on the period the rules cover. Ask counsel whether the firm must decline the reward, return it or decline the engagement, and document the decision.

Does the CPA have to share any client data to make the introduction?

No. A partner only makes the introduction and gives basic fit information. Partners never export, upload or describe confidential records. The company works directly with SourceX on its inventory, agrees de-identification and redaction requirements before any work begins, and data is delivered only after an executed agreement and the company's authorization.

Free resources

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

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