What is the difference between a commission and a referral fee under the AICPA Code?
Under the AICPA Code, a commission is pay for recommending or referring a product or service that someone else supplies, while a referral fee is pay for recommending a CPA's services or a payment made to obtain a client. A reward for introducing a client to a data licensing service such as SourceX therefore reads as a commission.
The one-line test: what did you recommend?
In the AICPA Code, a commission is compensation for recommending or referring a product or service that someone else supplies, while a referral fee is compensation for recommending or referring a CPA's services, or a payment made to obtain a client. Both sit in the Commissions and Referral Fees Rule, ET 1.520, in the AICPA Code of Professional Conduct. The practical consequence: the label follows the thing you recommended, not the word the payer uses. A program can call its payment a referral reward, a finder's fee or a bonus, and the Code may still treat it as a commission.
How to classify a payment in three questions
- What did you recommend? If it was the services of a CPA or CPA firm, the payment is a referral fee. If it was anything else, such as software, insurance, financing or a data licensing service, it is a commission.
- Which direction did the recommendation run? Recommending an outside product to your client and recommending your client's product or service to someone else are both commission situations under the rule.
- Is it the price of your own professional services, set by a result? Then you are looking at a contingent fee, which is a separate rule (ET 1.510). The New York State Society of CPAs explains that a contingent fee is one whose amount depends on attaining a specific result, and that it is barred for clients receiving audits, reviews, certain compilations or examinations of prospective financial information.
A payment from a third party for a recommendation normally lands in question 1 or 2, not question 3. If your own engagement fee is also tied to the outcome of the client's deal, ask your ethics adviser to look at both rules together.
Illustrative example: one payment, two outcomes
Illustrative: a regional firm prepares tax returns and runs the monthly close for a 140-person freight logistics company. The firm's advisory partner introduces the owner to SourceX, which manages the licensing of business records such as dispatch notes, support tickets and finance workflows to AI developers. If a license closes and SourceX collects its fee, the partner earns a referral reward.
Under the Code's definitions, that reward is a commission: the partner recommended a data licensing service supplied by a business that is not a CPA firm. Because the firm performs no audit, review, third-party compilation or forecast examination for the company, the Code allows it with disclosure, subject to the state rule. Change one fact, so that the same firm reviews the company's statements for its lender, and the same commission becomes prohibited for the covered period.
Commission, referral fee and related terms compared
| Term | What it pays for | Where the Code deals with it | Barred for attest clients? | Disclosure |
|---|---|---|---|---|
| Commission | Recommending a product or service supplied by another, or a client's product or service to others | ET 1.520 | Yes: audit, review, third-party compilation without an independence disclosure, forecast examination | Required where permitted |
| Referral fee | Recommending a CPA's services, or paying to obtain a client | ET 1.520 | Not part of the commission bar | Required, to the client |
| Contingent fee | Your own professional services, priced on a result | ET 1.510 | Yes, for the same attest categories | Governed by its own rule |
| Finder's fee | A business label with no Code definition | Classify by what was recommended | Depends on the classification | Depends on the classification |
| Revenue share or affiliate payout | A business label, usually tied to a vendor's product or service | Usually a commission | Usually yes | Usually required |
| SourceX referral reward | Introducing a company to a data licensing service | Reads as a commission | Yes, for those clients | Required where permitted |
Why the label matters for referral partners
Calling a payment a referral fee when it is really a commission can lead a firm to apply only the disclosure requirement and miss the attest-client bar entirely. For a CPA introducing companies to SourceX, the commission label means the first job is screening which clients bar a CPA from taking a commission, then checking the state rules where you practice.
The economics do not change the classification. 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. The reward comes out of SourceX's share and is never deducted from the company's proceeds, yet it is still compensation for a recommendation.
The label also says nothing about whether a company is worth introducing. For that, ask whether it is a US business that reached 50+ full-time employees at peak (contractors excluded), whether it holds several years of records across its systems, whether it can license them, and whether an executive will sponsor the work.
Related terms and pages
- Can a CPA accept a referral fee? applies the rule client by client.
- In legal ethics, referral fee carries a different meaning tied to fee-sharing rules; see can a lawyer accept a referral fee from a non-lawyer business.
This is general information, not legal, tax or financial advice. Confirm with your own counsel, tax adviser or professional body before acting.
Next step
Classify the payment first and screen the client second. If both checks clear, register as a partner and review the program terms before your first introduction.
- 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
If a program calls its payment a referral fee, is it a referral fee under the AICPA Code?
Not necessarily. The Code classifies by what the CPA recommended. A payment for recommending a CPA's services is a referral fee; a payment for recommending any other product or service is a commission, whatever the payer calls it. A data licensing, software or insurance program that labels its payout a referral fee is still paying a commission in the Code's terms.
Is a fee I receive from another CPA firm for sending them a client treated differently?
Yes. Being paid for recommending another CPA's services is a referral fee, which the rule permits with disclosure to the client and which sits outside the attest-client bar that applies to commissions. Paying a referral fee to win a client also has to be disclosed. State rules can add requirements to both, so check your board's text as well as the Code.
Can one payment be both a commission and a contingent fee?
The two rules address different things. A commission pays you for recommending someone else's product or service, while a contingent fee is the price of your own professional services set by a result. If a third party pays you for a recommendation and your own engagement fee also depends on the same transaction's outcome, both rules may apply, so review them together with your ethics adviser.
Does the commission label change anything for a tax-only client?
For a client that receives no audit, review, third-party compilation or forecast examination from your firm, the Code permits a commission as long as you disclose it. The label still matters because it tells you which disclosure applies and reminds you to recheck if the firm later takes on attest work for that client. State rules and firm policy may add conditions.
Related pages
Free resources
- Client opportunity brief generator — An editable intro email, summary and checklist.
- Days sales outstanding calculator — How many days customers take to pay.
- Business succession planning assessment — Ten questions on successor, transition and documentation.
- All free tools · MCP resource center
By SourceX Partnerships Team · Published 2026-10-09 · Updated 2026-10-09
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