Outside business activity policy: what to check before you join a referral program
Employees of consultancies, banks and accounting firms should treat a referral partnership as an outside business activity: read the policy, disclose the program and the possible reward in writing, and wait for approval before registering. Conflict, independence and inducement rules may require you to exclude certain clients, decline the reward or not take part at all.
Treat it as an outside activity until your employer says otherwise
The safe default is to assume your employer's outside business activity policy applies. Joining a referral program means taking on an outside role that could pay you, and the companies you know best are often your employer's clients. Both facts sit squarely inside what outside activity, conflict-of-interest and inducement policies are written to catch.
The policy may be called outside business interests, outside activities, personal independence, secondary employment or moonlighting. At a Big Four or other large professional services or financial firm it often lives on the intranet beside the gifts and hospitality rules, with a declaration form and a named compliance contact. Read your own version; what follows describes common features, not any particular firm.
What these policies usually cover
| Policy element | What it usually asks | How a referral partnership touches it |
|---|---|---|
| Outside activities register | Declare roles held outside the firm, paid or unpaid | Registering as a partner is an outside role |
| Pre-approval for paid work | Get sign-off before earning income outside your job | A reward is contingent income tied to a business deal |
| Conflicts of interest | Avoid personal gain that could sway advice to clients | Introducing a client you advise creates a possible conflict |
| Inducements and commissions | Limits on payments connected to clients or suppliers | The reward depends on a client's licensing deal |
| Independence | Restrictions for audit and assurance clients | Assurance clients may be off-limits entirely |
| Confidentiality | Client information stays inside the firm | You share basic fit information only, never records |
| Firm resources | No firm time, email, brand or data for outside work | Introductions come from you personally, not the firm |
Professional rules that sit above the policy
Some rules bind you whatever your employer's policy says.
- Registered representatives. On September 15, 2026 the SEC approved FINRA Rule 3290 (Outside Activities), which replaces Rules 3270 and 3280; FINRA will announce the effective date in a Regulatory Notice, and the existing rules apply until then, according to FINRA's weekly update. The new rule narrows which outside activities must be reported, so ask your compliance team how the firm treats a paid referral role before you start; firm policy can require more than the rule does.
- CPAs in public practice. Under the Commissions and Referral Fees Rule (ET 1.520) in the AICPA Code of Professional Conduct, a member may not accept a commission for recommending a product or service to a client when the member or firm 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.
- Lawyers. The ABA Model Rules of Professional Conduct, including Rule 1.5 on fees, Rule 5.4 on sharing fees with nonlawyers and Rule 7.2 on paying for recommendations, are a template that each state adopts in its own version, and rules outside the US differ again. Check with your bar or law society before accepting anything.
- Outside the US. Your home regulator or professional body may have its own inducement or referral-fee rules, and they apply even when the company you introduce is American.
This is general information, not legal, tax or financial advice. Confirm with your own counsel, compliance team or professional body before acting.
How to check, step by step
- Find the current policy. Search the intranet for outside activities, conflicts, and gifts and inducements; note the version date.
- Check client overlap. List the US companies you might introduce and run them through your firm's conflicts or independence system, noting which are clients and in what capacity.
- Write a short disclosure. Describe the program, your role (introductions only), how the reward is calculated and the fact that you will use no firm time, data or branding.
- Ask specific questions. May I accept the reward? Are any clients excluded? Must I tell the introduced company I may be paid? Does the approval expire?
- Keep the written answer. File the approval with your annual declarations and diarize any renewal date.
- Register only after approval. Then introduce only companies on the list you cleared.
What to put in the disclosure
Keep it factual, and describe the reward by formula rather than an amount.
Compliance will usually want the source documents, so attach the published program terms and point them to the referral earnings calculator, which shows how the formula works. If the company you would introduce is a client's US subsidiary, the note to a group CFO shows how to disclose the reward to the company in one sentence.
If the answer is no, or a conditional yes
| Employer answer | What it means | What you can do |
|---|---|---|
| Approved without conditions | You may take part | Keep the approval on file, then register |
| Approved, firm clients excluded | Clients are off-limits | Introduce only companies with no firm relationship |
| Activity allowed, payment not | You may not keep a reward | Do not register; tell a company it can apply directly at sourcex.si/apply |
| Not approved | The role conflicts with your job | Do not register or make introductions as a partner |
| No policy found | Silence is not approval | Disclose in writing to your manager and keep the reply |
When not to take part at all
- Your firm audits or provides assurance to the companies you would introduce, and the two cannot be separated.
- Your role gives you access to clients' confidential records, and the introduction would rest on what you saw there.
- You are a registered person and your firm will not approve the activity.
- You are serving notice or on garden leave and your contract restricts outside work.
If the company you have in mind is the US subsidiary of a group your firm serves in another country, run the conflicts check at group level; whether such a company can be referred at all is covered in referring a foreign-owned US company.
Next step
Get written approval first. When it arrives, work through the cross-border readiness checklist, then register as a partner.
- 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
Do I need approval if I plan to give the reward to charity?
Usually yes. Policies tend to focus on the activity and the potential conflict, not only on what you do with the money. A reward directed to charity can still look like an inducement linked to a client relationship. Describe the plan in writing and let compliance decide; some employers accept it and others do not.
Can I introduce a company that is a client of my employer?
Only if your policy and professional rules allow it, and often only with conditions. Audit and assurance clients carry the tightest restrictions for accountants. Even where it is allowed, rely only on what the client has told you openly, never on confidential records, and tell the company plainly that you may receive a reward.
Does my employer need to know if a reward may never be paid?
Yes. Policies usually cover the activity, not just the payment. A reward becomes payable only after the buyer pays and SourceX receives its fee, which can be long after the introduction, but the introduction itself is the outside activity. Disclosing before you start avoids a harder conversation later if a deal does close.
Should I tell the company I introduce that I may be paid?
Yes. Say plainly that you joined SourceX's partner program and could be paid part of SourceX's fee when a licensing deal closes, and that the reward comes out of SourceX's fee rather than the company's proceeds. Some professional rules require this disclosure, and it is good practice everywhere because it keeps the introduction honest.
Can my firm register as the partner instead of me?
Possibly, if the firm decides the activity fits its own policies and professional rules; anyone can join from any supported country. The firm would need its own internal approval first, and the program terms set who may register and on what basis. Read them before deciding, and never register on the firm's behalf without authority.
Related pages
Free resources
- Cash flow calculator — A 12-month cash forecast with shortfalls highlighted.
- Referral earnings calculator — Hypothetical partner earnings with the per-company cap.
- Cash conversion cycle calculator — DIO, DSO, DPO and the cash conversion cycle.
- All free tools · MCP resource center
By SourceX Partnerships Team · Published 2026-10-09 · Updated 2026-10-09
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