APES 110 and PES 1: can Australian and NZ accountants accept a referral commission?

Under APES 110 in Australia, and the New Zealand codes built on the same IESBA model, a referral fee or commission is not banned outright. It creates a self-interest threat you must identify, evaluate and address, for example through disclosure and the client's advance agreement. Assurance relationships, firm policy and tax-agent obligations can still rule a reward out.

The short answer: finish the threat assessment before you register

Australian and New Zealand accountants can sometimes accept a referral reward, but only after working through their code's threat assessment. APES 110 and the New Zealand codes follow the international IESBA model, which treats referral fees and commissions as something to evaluate and address rather than something banned in every case. In practice that means telling the client, getting its agreement before the introduction, and declining where the threat cannot be brought to an acceptable level, which is most likely where your firm does assurance work for the company.

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

Which code applies to you

Australia: APES 110 Code of Ethics for Professional Accountants (including Independence Standards), issued by the Accounting Professional and Ethical Standards Board. Members of the professional bodies that back the board are expected to comply. Read the section on fees and other types of remuneration, which covers referral fees and commissions.
New Zealand: PES 1 is the External Reporting Board's code for assurance practitioners. If you do not perform assurance work, check which code your professional body membership applies to your other services.
Registered tax and BAS agents: the Tax Practitioners Board's code of professional conduct applies as well, including its obligations on conflicts of interest.
Firm policy: your practice or network may have its own rules on external fees, and they can be stricter than the codes. Read them first.

The IESBA Code overview on referral fees explains the international text both countries build on.

A five-question threat assessment for a SourceX introduction

Write the answers down; they become your file note.

Relationship: is the US company a client of yours or your firm, and what services do you provide to it or its group?
Payment: who pays and on what basis? Here SourceX pays a share of its own fee, only after the buyer has paid, and the company's proceeds are not reduced.
Influence: could the reward affect advice the client relies on, for example if you are advising on a sale, a capital raise or the licensing decision itself?
Knowledge and agreement: does the client know about the reward, and will it agree to it in writing before the introduction?
Assurance: does your firm, or any firm in its network, audit or review the company or another entity in its group?

If the answers to 3 or 5 point to a significant threat that disclosure and agreement do not address, decline the reward. You can still make the introduction without one.

How it applies in common ANZ situations

Situation	What to check	Outcome to confirm with your body or firm
Virtual CFO for a Sydney scale-up that owns a US Inc. subsidiary	Fees and remuneration section, client knowledge and advance agreement	Written disclosure and agreement before the introduction
Audit partner at a firm auditing an ASX-listed parent with US operations	Independence Standards, firm policy, network rules	Treat a reward as a likely no; introduce without one if appropriate
Registered tax agent preparing returns for an Australian group with a US subsidiary	APES 110 plus the Tax Practitioners Board code on conflicts	Manage and document the conflict, or decline the reward
Chartered accountant in Auckland advising an exporter that bought a US distributor	Which code your membership applies, client agreement, firm policy	Disclosure and written agreement are the starting point
A US company met through an industry network, not a client	Firm policy and confidentiality of anything learned at work	Client-related provisions may not apply; policy still does
Firm that routes all referral income to the practice	Partnership agreement and firm policy	The firm, not the individual, registers as partner

Disclosure and consent, including US-facing publicity

A one-page disclosure before the introduction covers most situations.

Name SourceX as the payer and explain when a reward becomes payable
Describe the basis, 25% of eligible platform fees SourceX collects, capped at $100,000, without promising any amount
State that the reward comes from SourceX's fee and does not reduce the company's proceeds
Get the client's written agreement and its consent to share its name and basic fit information
Note your threat assessment on the client file and revisit it if assurance work begins

If you also recommend SourceX publicly to a US audience, for example in a newsletter or LinkedIn post that reaches US business owners, the US Federal Trade Commission's staff guidance on endorsements expects a material connection to be disclosed clearly and conspicuously, close to the recommendation. A plain statement that you are paid for referrals works better than a vague label.

Questions to ask CA ANZ, CPA Australia, IPA or your firm

Does a payment from SourceX for an introduction fall within the fees and remuneration provisions for my type of practice?
Is written disclosure enough here, or does the code expect the client's advance agreement as well?
Which provisions apply if I work in industry rather than in public practice?
If I am a registered tax agent, how should I document the conflict under the Tax Practitioners Board code?
Does any assurance relationship in the client's group rule the reward out?

Compare how other jurisdictions handle the same question: the ICAI rules for Indian CAs rest on statute, and Canadian CPAs check provincial codes.

Rewards and paperwork for ANZ partners

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 referral earnings calculator shows the formula, and the program terms govern the rest.

Before a payout, a US tax form is requested: an individual form for a person, an entity form for a practice, explained in the W-8BEN-E guide for advisory firms. Australian or New Zealand tax on the reward is a question for your own adviser.

Next step

File your threat assessment, get the client's written agreement, then register as a partner. The page for accountants explains which US companies tend to qualify.

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 APES 110 require the client's written consent before I accept a referral fee?

The code's approach is to evaluate the threat and take actions that address it, and disclosing the arrangement and obtaining the client's advance agreement are among the actions it contemplates. Whether written agreement is strictly required depends on your situation and firm policy. Getting it in writing before the introduction is the simplest way to show the threat was addressed.

Does PES 1 apply if I never do assurance work?

PES 1 is the code for assurance practitioners in New Zealand, so if you provide no assurance services it may not be the code that governs your other work. Your professional body membership still carries ethical obligations for non-assurance services. Check which code your membership applies, and ask your body if the position for advisory or tax work is unclear.

Can I introduce a US company that a firm in my network audits?

Treat that as an independence question before anything else. Network firms are generally considered together for independence purposes, so an audit or review relationship elsewhere in your network can make a reward inappropriate even if you personally do no assurance work. Ask your firm's independence or risk team before contacting the company, and consider introducing it without a reward.

Do I have to tell the client how much I will receive?

You cannot know the amount in advance, because the reward depends on the eligible platform fees SourceX actually collects if a deal completes. Disclose the basis instead: the payer, the share of SourceX's fee, the cap per company and the fact that payment follows the buyer's payment. Never promise or estimate a dollar figure to the client.

What if my firm's policy says no?

Firm policy binds you even where the code would allow a reward, so follow it. You can still help the client by making the introduction without registering as a partner for that company, or by pointing the company's CEO or CFO to apply directly. Your advice to the client should be the same either way.

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

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