Do CPAs have to disclose referral fees? What to tell clients, when and in what form

Yes. Under AICPA ET 1.520, a CPA who receives a permitted commission must disclose it to the person or business the product or service was recommended to, and a CPA who accepts a referral fee for recommending a CPA's services must disclose it to the client. Some states add form or timing rules, so disclose in writing before the introduction.

Yes, and the safest moment is before the introduction

The AICPA Code requires disclosure of every commission and referral fee it permits. Under ET 1.520 of the AICPA Code of Professional Conduct, a CPA in public practice who is paid, or expects to be paid, a permitted commission must tell the person or business to whom the product or service was recommended. A CPA who accepts a referral fee for recommending a CPA's services, or pays one to obtain a client, must tell the client.

The Code sets the duty; your state may set the form and timing. Some state rules go further than the AICPA text, and the state-by-state rules table shows where to look. Disclosure also only matters where the payment is permitted at all, so screen the client first against the list of clients that bar a CPA from taking a commission.

Who must be told, and when

Payment	Who must be told under 1.520	Good-practice timing
Commission for recommending another business's service, such as a SourceX introduction	The person or business you recommended it to, here the client company	In writing, before or with the introduction
Commission for referring your client's product or service to someone else	The person you referred it to	Before the referral
Referral fee received for recommending another CPA	The client	Before the client engages that CPA
Referral fee paid to obtain a new client	The client you obtained	At engagement

A referral reward from SourceX is a commission in the Code's terms, because the service recommended is supplied by a business that is not a CPA firm. The page on how the AICPA Code labels a reward explains the distinction.

What a complete disclosure says

A disclosure that only says you may be compensated leaves the client guessing. Cover seven points.

Element	Why it matters	Example wording
Who pays	Shows the money comes from a third party	SourceX pays the reward, not your company
What triggers it	Shows it depends on a completed deal	Only after a buyer pays and SourceX collects its fee
How it is calculated	Lets the client judge the size of your interest	25% of the eligible fees SourceX collects, capped at $100,000
Effect on the client	Answers the first question most owners ask	Never deducted from what your company receives
Client's choices	Shows the recommendation is not tied to your engagement	You can apply directly, or decline, and our work is unaffected
Your role	Sets expectations about data	I make the introduction only and never handle your records
Attest status	Shows you checked the bar	We do not audit, review or examine forecasts for your company

The program fact behind those rows: 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.

A disclosure sequence for a SourceX introduction

Screen the client entity for attest work and confirm your state's rule.
Send the written disclosure to the person who would sponsor a license: the owner, CEO, CFO or another authorized representative.
Ask for a written acknowledgement. A reply email or a countersigned letter both leave a record.
Make the introduction through your referral link or the referral form, sharing basic fit facts only, such as headcount and years in operation.
File the disclosure and acknowledgement in the client's permanent file.
Tell the client if the program terms or your role change before any deal closes.
When a reward is paid, record it under the firm's policy on outside compensation.

After step 4 the work moves to the company and SourceX: qualification, a data inventory, agreement on price and terms, buyer review, and signature only if the company accepts the terms.

A disclosure letter you can adapt

Dear {first_name}, Before I introduce {company_name} to SourceX, I want to tell you about a financial interest I have in that introduction. I am a registered SourceX referral partner. If {company_name} licenses data through SourceX and SourceX collects its fee, SourceX will pay me a referral reward calculated as 25% of the eligible platform fees it collects from your deals, capped at $100,000. The reward comes out of SourceX's fee. It is not added to your price and is not deducted from what {company_name} receives. Our firm does not perform audit, review, third-party compilation or forecast examination services for {company_name}. You are free to apply to SourceX directly or not at all, and our engagement is unaffected either way. Please reply to confirm you have read this disclosure. {your_name}, {firm_name}

Public posts need their own disclosure

If you mention the program in a client newsletter, webinar or LinkedIn post, the FTC's guidance on endorsements says a material connection, such as being paid for referrals, should be disclosed clearly and close to the recommendation (FTC Endorsement Guides FAQ). A plain statement next to the link that you receive a referral reward if a company you introduce licenses data through SourceX works better than a footer note.

Mistakes that undo a good disclosure

Mistake	Why it hurts	Fix
Disclosing after the client has applied	The client decided without the information	Disclose before or with the introduction
Burying it in engagement letter boilerplate	Easy to miss and hard to prove it was read	Send a separate short letter or email
Estimating the reward in dollars	No amount exists until a deal closes, and a figure reads like a promise	Describe the formula and trigger instead
Implying the client funds the reward	Inaccurate	State that it comes from SourceX's fee
Disclosing to a manager without authority	The decision-maker may never see it	Address the owner, CEO or CFO

Questions for your counsel or state board

Does our state require written disclosure, and must it come before the recommendation?
Must the disclosure describe how the payment is calculated, or only that it exists?
Does the state require a signed acknowledgement from the client?
If I also hold an investment adviser or securities registration, which additional disclosure rules apply? The page on whether an RIA can accept a third-party referral fee covers that side.

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

Next step

Adapt the letter to your state's rule and send it with your first introduction. Then register as a partner and read the program terms so the formula in your disclosure matches the published program.

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 a sentence in our engagement letter enough disclosure?

It may satisfy a bare requirement in some cases, but it is weak evidence that the client understood a specific payment. Engagement letters are signed once and skimmed. A short, separate letter or email sent with the introduction names the payer, the trigger and the formula, and gives you a dated acknowledgement. Check whether your state rule specifies form or timing before relying on boilerplate.

Do I have to disclose if the client never licenses any data?

Disclose at the time you make the recommendation, because the duty attaches when you expect to be paid, not only once money arrives. If the company never signs a license, no reward is paid and nothing further is owed, but the disclosure still belongs in the file. It shows the client heard about your interest before deciding whether to engage.

Do I need to tell the client a dollar amount?

No amount exists at introduction time, because the reward depends on fees SourceX actually collects from deals that may never happen. Describe the calculation instead: the published rate applied to eligible platform fees, the per-company cap, and the payment trigger. Avoid estimating dollars, which can read as a promise. If your state requires the basis of calculation, the formula satisfies that better than a guess.

Who at the client company should receive the disclosure?

Send it to the person with authority to decide on a license: the owner, CEO, CFO or another authorized representative who would sponsor the work. Copying the controller or office manager is fine, but a disclosure that reaches only staff without decision authority does little to protect you or inform the client. Address the company and its decision-maker by name.

Does FTC guidance apply to a private email to one client?

The FTC's endorsement guidance is aimed at marketing messages such as posts, newsletters and reviews. A one-to-one recommendation to a client is governed mainly by your professional rules, which already require disclosure of a permitted commission. The practical answer is the same in both settings: say plainly that you are paid if the introduction leads to a deal, and say it before the client acts.

Free resources

MOIC calculator — Multiple on invested capital from realized and unrealized value.
PDF bank statement to CSV converter — Turn Chase, Bank of America or Wells Fargo PDF statements into CSV, privately in your browser.
Client data licensing eligibility checker — A transparent preliminary screen for one company.
All free tools · MCP resource center

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

Know a US company with valuable proprietary data?

Become a referral partner from anywhere we support, get your link and introduce an owner or authorized decision-maker.

Refer a company →

I own a business

Explore licensing your company's data to AI developers worldwide. Start a short assessment; no uploads needed.

Start an assessment