Can a Dutch accountant accept a referral fee under NBA rules?
Whether a Dutch accountant may accept a referral fee depends on NBA membership, whether the firm does assurance work for the company, how the reward is structured and whether it is disclosed. Read the NBA rules and confirm with the NBA before registering as a partner.
Can a Dutch accountant accept a referral fee?
It depends on whether you are a member of the NBA, what services your firm provides to the client and the current text of the professional rules that bind you. Dutch accountants should check the NBA's conduct and professional rules (often referred to by the abbreviation VGBA), plus the independence provisions that apply to assurance work, before accepting any reward for introducing a company.
Rule text is not reproduced here. The answer you act on should come from the NBA's own current rules and its ethics support, not from a summary of them.
Which questions decide it?
Independence and objectivity are the usual center of gravity. Work through these in order.
| Question | Why it matters | Check |
|---|---|---|
| Do you or your firm perform assurance work for the company? | Independence is strictest for assurance clients | The independence provisions in your rules |
| Is the reward a commission for recommending a product or service? | Commission can look like a financial interest in the advice | The fees and remuneration provisions |
| Is it contingent on the company signing a deal? | Contingent outcomes raise self-interest concerns | Same provisions and NBA guidance |
| Is the arrangement disclosed to the client? | Disclosure lets the client weigh any bias | Disclosure wording in the rules |
| Are you acting as an accountant or in a separate capacity? | Outside capacities may still be covered | Rules on other activities and your firm policy |
The US offers a reference point, nothing more: the AICPA Code's Commissions and Referral Fees Rule (ET 1.520) mainly applies where the firm does attest work for the client, per the AICPA Code hosted by the Minnesota Society of CPAs. US state boards can be stricter, as the New Jersey Society of CPAs page shows. It is not Dutch law or NBA practice.
How does independence play out in common situations?
| Situation | What to check | Outcome to confirm |
|---|---|---|
| Company is a statutory audit client | Independence rules on any benefit from the client or a related deal | Independence is the central issue; confirm with the NBA |
| Advisory client, no assurance work | Commission and disclosure provisions | Whether written disclosure and consent suffice |
| Introduction from a personal network, not a client | Whether the accountant title or firm is involved | Whether any professional rule is engaged |
| Fee paid to your holding company instead | Whether that changes the analysis | Ask the NBA rather than assuming |
What exactly are you introducing?
A US company with 50+ full-time employees at peak (contractors excluded), several years of documented operations, rights to license its data and an authorized sponsor. You make the introduction and share basic fit information only. You never export, upload or describe records. For a Dutch practice with US subsidiaries of Dutch clients, the US entity must own the rights to the data, which is a question the company confirms, not you.
Partners earn 25% of eligible platform fees SourceX actually collects, capped at $100,000 per referred company. The reward is payable only after the buyer pays and SourceX receives its fee, and no reward is guaranteed. See the program terms.
Disclosure and consent in practice
Document three things on the client file before any introduction: that the reward exists, that the client is free to decline, and that the client agreed to the introduction. For an assurance client, assume the answer is no until the NBA confirms otherwise.
A short file note reads: "Client was told that I may receive a reward from the referral partner if it licenses data through the platform; client consented to the introduction on {date}; no reward depends on advice given."
Questions to ask the NBA or your compliance officer
- Does any rule restrict a reward for introducing a company that is not an audit client?
- Is written disclosure sufficient, and what must it contain?
- Does my answer change if the reward is paid to a separate legal entity?
- Do I need the partner board's approval under our own firm policy?
For neighbouring jurisdictions see Irish accountants, Singapore accountants, and the general page for accountants and bookkeeping firms. Anti-corruption angles are in the page on the UK Bribery Act and referral fees. Background on how agreements are structured is in what a referral fee agreement is. If you are non-US, can non-US residents join and the W-8BEN-E walkthrough cover eligibility and tax forms.
This is general information, not legal, tax or financial advice. Confirm with your own counsel, tax adviser or professional body before acting.
Next step
Get a written answer from the NBA or your compliance function. If it allows the arrangement, register as a partner and test the formula in the referral earnings calculator.
- 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 referral fee allowed for Dutch accountants?
No. This page cannot say. The answer turns on your status, whether the firm does assurance work for the company, how the reward is structured and whether it is disclosed. Read the NBA's current rules and ask its ethics support before registering.
What does VGBA refer to?
It is the abbreviation commonly used for the NBA's conduct and professional rules for accountants. Check the current version on the NBA's own site, because rules are amended, and read the provisions on independence, fees and other activities. Do not rely on a summary, including this one, for what the text says today.
Does it matter whether the company is my audit client?
Very likely, since independence provisions bite hardest on assurance clients. The US AICPA rule on commissions similarly centers on attest clients, but that is only a comparison. For an audit client, assume the answer is no until the NBA confirms otherwise in writing.
Can the reward go to my holding company?
That may change the tax, contracting and ethics analysis, and you should not assume it solves a professional-rule problem. Ask the NBA whether routing the reward through another entity affects your obligations. Decide the receiving party before you register so forms and bank details match.
When is the reward actually paid?
Only after the buyer pays and SourceX receives its fee, and the amount is 25% of eligible platform fees, capped at $100,000 per referred company. A lead, a meeting or a signed agreement alone does not trigger payment, and no reward is guaranteed.
Related pages
- Can Irish accountants accept commissions or referral fees under their code?
- Can Singapore accountants accept a referral commission from SourceX?
- Referral opportunities for accountants and bookkeeping firms
- UK Bribery Act and referral fees: what disclosure and adequate procedures mean
- What is a referral fee agreement?
- Can non-US residents join the SourceX referral program?
Free resources
- Working capital calculator — Net working capital, current ratio and quick ratio.
- Due diligence checklist generator — A tailored document request list by deal type.
- Cash flow calculator — A 12-month cash forecast with shortfalls highlighted.
- All free tools · MCP resource center
By SourceX Partnerships Team · Published 2026-10-09 · Updated 2026-10-09
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