Can a CPA accept a referral fee or commission? What AICPA Rule 1.520 allows

The short answer: it depends on the client

A CPA in public practice can accept a commission or referral fee for some clients and not for others. The dividing line in the AICPA Code of Professional Conduct is attest work: if the firm audits or reviews a client's financial statements, compiles statements a third party will rely on without disclosing a lack of independence, or examines the client's prospective financial information, a commission tied to that client is off the table. For other clients, the Code permits the payment as long as it is disclosed.

That is the AICPA layer only. Your license comes from a state board, and some boards add their own text, form requirements or restrictions. Check the CPA commission and referral fee rules by state before relying on the Code alone.

What ET 1.520 actually says

The Commissions and Referral Fees Rule (ET 1.520.001) has four working parts. The summary below is a paraphrase; read the current text on the AICPA site before you act.

• Prohibited commissions: a member in public practice may not recommend a product or service to a client for a commission, refer a client's product or service to others for a commission, or receive a commission, when the member or the member's firm also performs an audit or review, a compilation expected to be used by a third party without an independence disclosure, or an examination of prospective financial information for that client.
• Covered period: the prohibition runs through the period of the attest engagement and the period covered by the historical financial statements involved.
• Permitted commissions: where no prohibition applies, the member must disclose the commission to the person or business to whom the product or service was recommended.
• Referral fees: a member who accepts a fee for recommending or referring a CPA's services, or who pays one to obtain a client, must disclose it to the client.

Whether a payment is a commission or a referral fee depends on what was recommended, not on the name the payer gives it. The explainer on how the AICPA Code labels a reward walks through that test.

A decision table by client relationship

Treat this as a screen to discuss with your ethics partner, not a substitute for that conversation. A firm with mixed engagements across a client group should run it entity by entity.

How the rule applies to a SourceX introduction

SourceX pays partners for introducing US companies that license their operational records to AI developers through its platform. 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.

Three facts shape the analysis:

1. The payment comes from SourceX for recommending a service that a non-CPA business supplies, which points to the Code's commission category rather than its referral fee category.
2. The reward is a share of SourceX's fee and is never deducted from what the client receives. That helps the client relationship, but it does not lift the attest-client prohibition, because the rule turns on the services your firm performs, not on who bears the cost.
3. Your role ends at the introduction. With the client's permission you pass on basic fit information; the company works with SourceX on qualification, its data inventory, pricing and contracting, and no records move without a signed agreement.

Before raising it, check fit. SourceX looks for US companies with 50+ full-time employees at peak (contractors excluded), several years of documented operations, the right to license their records and an owner or senior executive able to sponsor the work. The company fit checker gives a quick, non-binding read.

A disclosure script for non-attest clients

Say it before the introduction, then confirm it in writing.

Questions to settle with your ethics partner or state board

• Does any partner, office or network firm perform an audit, review, third-party compilation or forecast examination for this client or its affiliates?
• Does our state adopt the AICPA interpretations by reference, or does it have its own statute or board rule?
• Does the state specify written disclosure, advance disclosure or a description of how the payment is calculated?
• Does our partnership agreement require outside referral income to be paid to the firm?
• If the client later asks for a review or audit, how do we treat a reward that is still pending?

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

When to skip the introduction

• The firm performs any listed attest service for the client in a covered period.
• The client's records mostly belong to its own customers, as with an outsourced bookkeeping or payroll provider, and those customers have not consented.
• The company never reached 50+ full-time employees at peak, or old systems were shut down without an export.
• The owner would not consider an exclusive license for AI training for an agreed term.

Other professions answer this question under different rules. Lawyers, for example, face fee-sharing limits covered in can a lawyer accept a referral fee from a non-lawyer business.

Next step

Screen one non-attest client this week. If the client fits and your state rule allows it, register as a partner, read the program terms, and see the wider referral opportunities for accountants.