IESBA Code: can a professional accountant accept a referral fee or commission?

The IESBA Code does not ban referral fees or commissions outright for accountants in public practice. It treats them as creating a self-interest threat that must be identified, evaluated and addressed, and it describes disclosure to the client and the client's advance agreement as possible actions. National codes built on it can be stricter, and audit clients add independence rules.

The short answer: permitted only after the threat is addressed

The International Code of Ethics for Professional Accountants, issued by the International Ethics Standards Board for Accountants (IESBA), does not answer the referral-fee question with a flat yes or no. In broad terms, a referral fee or commission connected with a client creates a self-interest threat to objectivity and to professional competence and due care. You identify that threat, evaluate it and address it; where nothing brings it to an acceptable level, you decline the fee.

Two things then narrow the answer. Your national body may have adopted the Code with stricter local provisions, or sit under statute that goes further. And if your firm audits or reviews the company, the Code's independence standards apply on top of the general rules. Read the edition your body has adopted, not a summary, including this one.

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

Where the Code deals with fees and commissions

The Code is organized in parts. For a referral reward, these are the places to read; check the numbering in the edition your body uses.

Part of the Code	Who it covers	What to read for a referral reward
Part 1	Every professional accountant	The fundamental principles and the conceptual framework for identifying, evaluating and addressing threats
Part 2	Accountants in business	Conflicts of interest, inducements, and financial interests or incentives linked to decisions you influence
Part 3	Accountants in public practice	The section on fees and other types of remuneration, which covers referral fees and commissions, plus the section on inducements
Part 4A	Audit and review engagements	International Independence Standards, including fee-related provisions for audit clients
Part 4B	Other assurance engagements	Independence for assurance work other than audits and reviews

How the threats-and-safeguards approach works

Apply it to the specific introduction, not to the program in general.

Name the principles at risk. A reward tied to a client's decision mainly tests objectivity and professional competence and due care.
Identify the threat. It is usually self-interest: you gain if the client proceeds.
Evaluate it. Consider whether the company is a client, what you advise it on, whether the reward could shape that advice, and whether the client knows.
Address it. Actions the Code describes for referral fees and commissions include disclosing the arrangement to the client and, for some arrangements, obtaining the client's advance agreement. If those do not bring the threat to an acceptable level, decline the reward.
Document it. Keep the evaluation and the client's agreement on file, and revisit both if your role changes, for example if assurance work begins.

How national codes and laws build on it

Many national bodies adopt the IESBA Code with local changes; some jurisdictions add statute that takes priority. Start with your own framework.

Where you are licensed	What to read first	Guide on this site
United Kingdom	ICAEW or ACCA code, plus firm policy	ICAEW and ACCA members
Canada	Your provincial or regional body's code	Canadian CPAs
Germany	StBerG or WPO and the professional by-laws	Steuerberater and Wirtschaftsprüfer
India	The Chartered Accountants Act Schedules and the ICAI Code	Indian CAs
Australia and New Zealand	APES 110, PES 1 and the codes of your body	ANZ accountants
Elsewhere	Your national body's code and any statute on professional fees	Ask your body which edition applies

The US uses its own code

US CPAs follow the AICPA Code and their state board's rules rather than the IESBA text. Under the AICPA's commissions and referral fees rule, ET 1.520, a member in public practice may not accept 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 permitted commissions and referral fees must be disclosed to the client. State boards can be stricter. If you hold a US license as well as a national one, meet the stricter rule.

Applying it to common situations

Situation	Main threat	Where the Code points you
Advisory or tax client, no assurance work anywhere in the group	Self-interest	Disclosure and the client's advance agreement, then a documented evaluation
Your firm audits or reviews the company	Self-interest and independence	The independence standards; a reward is hard to reconcile with them
A network firm audits another entity in the group	Independence across the network	Your firm's independence function before any contact
You are advising the client on the licensing decision itself	Self-interest at its strongest	Consider declining the reward and saying so
You work in industry and the company is your employer's affiliate	Conflict of interest	The Part 2 provisions and your employer's policy
The company is a contact, not a client	Professional behavior and confidentiality	Firm policy and the general principles still apply

Questions to ask your national body

Has our body adopted the current IESBA provisions on fees and remuneration, and with what local changes?
Does a payment from a non-accountant business for an introduction count as a referral fee or commission under our code?
Is the client's advance agreement required, or is disclosure enough in my situation?
Which statute, if any, overrides the code where I am licensed?

Firms serving clients in several countries can use the playbook for international accounting firms to set one policy across offices.

How the SourceX reward works

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; an introduction or signed agreement alone triggers nothing, and no reward is guaranteed. The reward is a share of SourceX's fee and is never deducted from what the company receives, which is worth stating in any disclosure. Partners only make introductions; they never export, upload or describe client records.

Next step

Work through the five steps above, record the outcome, and if a reward is appropriate, 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 the IESBA Code apply to me directly?

Usually not directly. The IESBA Code applies through national bodies and regulators that adopt it, sometimes with local changes, and some jurisdictions add statute on top. The version that binds you is the one your professional body or regulator has adopted. Read that edition, and treat the international text as background rather than as the rule you are measured against.

Is a referral fee the same thing as a commission under the Code?

The Code deals with both in the same part of its fees and remuneration provisions, and both raise a self-interest threat. Broadly, a referral fee is received for referring a client to someone, while a commission is linked to the sale of goods or services to a client. A SourceX reward for introducing a company sits close to a referral fee, but check how your national code classifies it.

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

This is where the answer is most likely to be no. The independence standards apply on top of the general fee provisions, and a reward that depends on an audit client's transaction is difficult to reconcile with them. Speak to your firm's independence function first. You can usually still make the introduction without accepting any reward, if the client wants it.

Is disclosure to the client always enough?

No. Disclosure and the client's advance agreement are actions that can address the threat, but they do not cure every situation. If you are advising the client on the decision that triggers the reward, or your firm provides assurance services to it, the threat may remain too high whatever the client agrees to. In that case the Code's logic points to declining the reward.

Should I keep a record of my evaluation?

Yes. A short file note showing the relationship, the threat you identified, how you evaluated it and the action you took, together with the client's written agreement, shows you applied the framework properly. Review it if your role with the client changes, for example if your firm is later appointed to perform assurance work for the company or its group.

Free resources

Earnout scenario calculator — Probability-weighted earnout value and its present value.
Profit margin calculator — Profit and margin across three scenarios.
Client opportunity brief generator — An editable intro email, summary and checklist.
All free tools · MCP resource center

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

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