ICAEW and ACCA members: can you accept a referral fee, and what must you disclose?

Whether an ICAEW or ACCA member in practice may accept a referral fee depends on the facts and on the current text of their own code. Both follow the IESBA approach, which treats referral fees and commissions as a self-interest threat, often addressed by disclosure and client agreement. Audit work and firm policy can rule a reward out.

The short answer: it depends on the client, your role and your firm

Neither the ICAEW Code of Ethics nor ACCA's Code of Ethics and Conduct gives a yes-or-no answer in the abstract. This page does not quote either code, so read the current text on your body's website. As we understand them, both follow the IESBA Code, which treats a referral fee or commission connected to a client as creating a self-interest threat to objectivity and to professional competence and due care. Before you accept one, you identify that threat, evaluate it and address it. The usual ways of addressing it are telling the client about the arrangement and obtaining its agreement in advance; where neither is enough, you decline the fee.

Audit relationships change the picture. If your firm audits the company, the FRC's Ethical Standard and the independence provisions of your code apply on top of the general rules, and a reward linked to that company's transaction is hard to reconcile with them. Firm policy can be stricter still.

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

What do the codes actually require?

Both bodies follow the IESBA structure, in which the section on fees and other types of remuneration for accountants in public practice deals with referral fees and commissions. Read the current text on your own body's website rather than a summary. In outline, it asks you to:

Identify the threat. A referral fee or commission relating to a client can create a self-interest threat to objectivity and to professional competence and due care.
Evaluate it. Consider the nature of the arrangement, whether the client knows about it, and whether it could influence the advice you give.
Address it. Responses commonly drawn from IESBA-based guidance include disclosing referral fees or commission arrangements to the client and obtaining the client's advance agreement. If nothing brings the threat to an acceptable level, decline.

Two other layers sit alongside the code. Your confidentiality duty means you share nothing about a client with a third party without authority, which fits a program where partners give basic fit information only and never export, upload or describe confidential records. And where you act as the client's agent or in a position of trust, general law on secret commissions may require full disclosure and the client's informed consent, whatever the ethics code says.

If you also hold a US license

Members who are also US CPAs carry a second code. Under the AICPA Code of Professional Conduct, the commissions and referral fees rule, ET 1.520, bars a member in public practice from accepting a commission for recommending a product or service to a client when the member or firm also performs an audit, review, certain compilations or an examination of prospective financial information for that client, and requires permitted commissions and referral fees to be disclosed to the client. US state boards can be stricter. Where two codes apply, follow the stricter one.

How it applies in common UK practice situations

Situation	What to check	Typical outcome to confirm with your body or firm
Outsourced finance or business-advisory client, no assurance work	Whether the client knows about and agrees to the arrangement before the introduction	Written disclosure and advance agreement are the usual way to address the threat
Your firm audits the company you would introduce	FRC Ethical Standard, independence provisions and firm policy	Often a reason to decline the reward, or to make the introduction without one
You work in industry, for example as finance director of the company	The part of the code for accountants in business, and your employer's conflict policy	A personal reward from your own employer's deal raises a conflict; raise it with the board first
You are a partner or employee in a practice	Firm policy and your partnership deed or contract	Many firms require external fees to be paid to the firm and logged
You are dual-qualified as a US CPA	AICPA ET 1.520 and your state board's rule, alongside your UK code	Follow whichever rule is stricter
You hold an insolvency license and the company is in an appointment	The insolvency code of ethics and your duties to creditors	Personal rewards linked to estate assets are unlikely to be appropriate; take advice

Disclosure and consent good practice

Disclose before you introduce, do it in writing, and keep the client's agreement on file.

Tell the client before the introduction, not after a deal closes
Name the payer (SourceX) and describe the basis of the reward and when it is paid
Confirm that the reward comes out of SourceX's fee and does not reduce what the client receives
State that your advice does not depend on whether the client proceeds
Obtain the client's written agreement and file it with the engagement records
Record your threat assessment, and revisit it if the firm later takes on assurance work for the client

A disclosure note can be short:

If the client asks how the share is worked out, the referral earnings calculator shows the published formula without promising any amount.

How the reward works, in program terms

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, and the reward becomes payable only after the buyer pays and SourceX receives its fee. No reward is guaranteed, and a lead, meeting or signed agreement alone triggers nothing.

If your firm rather than you is the partner of record, expect to complete the entity version of the US tax form; the W-8BEN-E guide for advisory firms walks through it, and how US referral rewards are taxed for UK residents covers the income tax side. Read the program terms before registering.

Questions to ask your professional body or firm

Does my firm provide audit, review or any other assurance service to this company or a related entity?
Does firm policy require external fees to be paid to the firm, and who signs off on them?
Is disclosure enough here, or do I also need the client's advance agreement in writing?
Does my engagement letter already deal with commissions and referral fees, and does it need updating?
If I hold another license, such as a US CPA license or an insolvency license, which extra rules apply?

Both bodies offer members ethics support. Use it when the answer is not obvious, and keep a note of the advice you receive.

When to decline

The firm audits the company, or provides other assurance work that makes the reward incompatible with independence.
The client will not agree to the arrangement once it is disclosed.
The reward could colour advice the client is relying on, for example while you are advising on a sale or a refinancing.
Firm policy prohibits personal referral fees.

Declining the reward does not stop you helping. The company can still be introduced without any reward to you, or apply to SourceX directly.

Next step

Once you have checked your code and your firm's policy, register as a partner. The page for accountants covers which clients tend to fit, and the IESBA Code overview on referral fees and commissions sets out the international baseline both UK codes build on.

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 telling the client enough, or do I need their agreement as well?

The IESBA-based codes describe both disclosure and advance agreement as ways to address the threat, and which one you need depends on the arrangement and your evaluation. Many firms require both in writing as a matter of policy. Where you act as the client's agent, general law on secret commissions may also call for informed consent, so written agreement before the introduction covers both concerns.

Can I accept a referral reward relating to an audit client?

This is where the rules are strictest. The FRC's Ethical Standard and the independence provisions of your code apply on top of the general fee rules, and a reward linked to an audited entity's transaction is hard to reconcile with them. Many firms treat it as off-limits. Speak to your ethics partner before any introduction, and consider making the introduction without accepting a reward.

Do these rules apply to accountants working in industry?

A different part of the code applies to accountants in business, built around conflicts of interest and duties to your employer. If you are the finance director of the company, a personal reward from its own licensing deal is a conflict to raise with the board before anything else. If you introduce a different company, check your employment contract and your employer's outside-interest policy first.

Should the reward be paid to me or to my firm?

Your partnership deed, employment contract and firm policy usually answer this, and many practices require fees earned through client relationships to go to the firm. The choice also changes the paperwork: a firm registers in its own name, completes the entity version of the US tax form and accounts for the income itself. Settle it before registering rather than when the first payment arrives.

Does making the introduction risk breaching client confidentiality?

Only if you share more than the client has authorized. An introduction needs the client's name, a contact and basic fit information, so get the client's permission before passing anything on, ideally in the same note that discloses the reward. Partners never export, upload or describe confidential records; the company deals directly with SourceX on its inventory, rights review and contracting.

Free resources

Business DSCR calculator — Debt service coverage from cash flow and loan terms.
MCP ROI calculator — Estimate hours saved, implied savings and first-year ROI from MCP.
Business exit readiness assessment — A preliminary exit readiness score and checklist for advisors.
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