ICAI rules on referral fees and commissions: what an Indian CA should check first

An Indian chartered accountant should not accept a referral reward until the ICAI position is clear. The Chartered Accountants Act, 1949 lists professional misconduct in its Schedules, including items on commission, brokerage and sharing fees, and the ICAI Code of Ethics explains them. The answer turns on practice status, the client relationship and who pays.

The short answer: status, client and payer decide

For a chartered accountant the question has two layers. The Chartered Accountants Act, 1949 sets out acts of professional misconduct in its Schedules, and several items deal with commission, brokerage and sharing fees or profits with people who are not members. The ICAI Code of Ethics explains how the Institute reads those items. The Schedules group misconduct by status: members in practice, members in service and members generally.

So the answer for a SourceX referral reward depends on three facts: whether you hold a certificate of practice or work in employment, whether the US company is your client or your firm's client, and how the Institute treats a payment from a non-member business for an introduction. This page does not paraphrase the clauses; read the current text of the Act and the latest edition of the Code.

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

What to read before you decide

The commission and fee-sharing items in the Schedules: read the exact wording on paying or accepting commission, brokerage, or a share of fees or profits, and note which status each item applies to.
The Code's explanation of those items: the Code of Ethics sets out how the Institute interprets them, with examples. Use the edition in force on the date you would register.
Other business or occupation: if you are in practice, check whether acting as a paid referral partner would count as another business or occupation and whether it needs the Council's permission.
Confidentiality: disclosing information about a client without its consent is a separate concern from the fee itself.
Firm and network policy: a firm that belongs to an international network may apply rules stricter than the Act.

How it applies in common situations for Indian CAs

Situation	What to check	Outcome to confirm with ICAI or your firm
Your practice does outsourced bookkeeping or tax preparation for US CPA firms	Who your client is: the US CPA firm, not the end company; confidentiality terms in your service agreement	Treat the end companies as off-limits; never use records you process to find leads
You advise an Indian group that owns a US subsidiary	Commission items for members in practice, other-occupation permission, the client's consent	Whether any reward is allowed; if not, introduce without one
You are a CA in service at a US company's India capability center	Items for members in service, your employer's outside-activity and conflict policy	Raise it with your employer first; a personal reward from your own employer's deal is a conflict
Your firm audits the Indian subsidiary of a US group	Independence requirements, the fee items and network policy	Treat a reward linked to that group as a likely no
You also hold a US CPA license	ICAI rules plus the rules of the US state that licensed you	Meet whichever is stricter
The US company is a business contact, not a client	Whether the practice-related items still apply to you as a member	Confirm before registering

The outsourcing case deserves emphasis. A firm that processes a US company's books on behalf of a US CPA firm holds records that belong to someone else, and introducing that end company on the strength of what you have seen would breach the trust the arrangement depends on. Data that belongs to an outsourcer's clients is also a red flag for any licensing deal unless those clients consent.

Disclosure and consent good practice

If the Institute's position allows a reward in your situation, keep the paper trail tight.

Record the basis on which you concluded the reward is permitted, with any written view from ICAI
Obtain the client's written consent before sharing its name, a contact and basic fit information
Disclose in writing that SourceX pays the reward, what it is based on and when it becomes payable
Confirm that the reward comes from SourceX's fee and does not reduce the company's proceeds
Keep your professional advice independent of whether the company goes ahead
Never share ledgers, returns or exports; the company works with SourceX directly

Questions to put to ICAI or your firm's ethics lead

Does a payment from a non-member business for introducing a client fall within the commission or brokerage items for members in practice?
Does acting as a referral partner require the Council's permission as another occupation?
Is the position different for a member in service, or for an introduction of a company that is not a client?
Does it matter whether the reward is paid to me or to my firm?
If my firm is part of an international network, which policy governs?

For the international model that many national codes build on, see the IESBA Code overview on referral fees. Colleagues elsewhere face different rules: compare the ICAEW and ACCA position or the provincial rules for Canadian CPAs.

Rewards and paperwork for partners in India

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 rewards are not guaranteed. The program terms set the details.

An individual partner resident in India gives the payer a Form W-8BEN when requested, whether or not a treaty rate is claimed; the form goes to the payer, not to the IRS. A firm registering in its own name uses the entity form instead, explained in the W-8BEN-E guide for advisory firms. Indian income tax and the treatment of the foreign remittance are questions for your own tax adviser.

Next step

Once the ICAI position is clear for your status and client, register as a partner. The page for accountants explains which US companies tend to fit.

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 it help if the reward is paid to my firm rather than to me?

It changes who signs the partner agreement and which US tax form is completed, but it does not by itself answer the ethics question. The commission and fee-sharing items may reach a firm's arrangements as well as an individual member's. Put the exact structure to the Institute or your firm's ethics lead, and settle the payee before registering rather than after an introduction.

Can a CA in employment register as a referral partner?

Possibly, but check two things. First, the items in the Schedules that apply to members in service. Second, your employer's policy on outside activities and conflicts, which may need approval before you take part. If the company you would introduce is your employer or one of its affiliates, the conflict with your employer is the issue to resolve first.

Can I introduce an end client of the US CPA firm I do outsourced work for?

Treat that as off-limits. Your client is the US CPA firm, and what you know about its clients comes from confidential work. Using it to make an introduction would breach that trust and probably your service agreement. The records you process also belong to someone else, which is a red flag for any licensing deal without that owner's consent.

Is the ICAI Code the same as the IESBA Code?

The ICAI Code draws on the international model, but the Schedules to the Chartered Accountants Act are Indian law with their own items of professional misconduct. Where the Act or the Institute's interpretation is stricter, that governs you. Read both the Act and the current edition of the Code rather than relying on a summary of the international text.

What information would I give SourceX about a company?

Only the company's name, a contact such as the owner, CEO or CFO, and basic fit information like approximate headcount at peak and years of operation, all with the company's consent. You never export, upload or describe confidential records. The company completes its own data inventory and agrees redaction rules, price and terms directly with SourceX.

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

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