Can a retired CPA earn referral rewards from former clients?

Short answer

A retired CPA may be able to earn a referral reward, but retirement alone does not settle it. The AICPA referral-fee rule centers on members in public practice and attest clients, and state boards add their own rules. Confirm your exact status with your state board in writing before accepting a reward.

Can a retired CPA earn referral rewards from former clients?: overview of The short answer: retired status may change the analysis, but it does not settle it, What the AICPA Code says about referral fees, Why the state board may matter more than the Code, How status changes the questions, The retiree checklist
Covered on this page: The short answer: retired status may change the analysis, but it does not settle it · What the AICPA Code says about referral fees · Why the state board may matter more than the Code · How status changes the questions · The retiree checklist

The short answer: retired status may change the analysis, but it does not settle it

A retired CPA may be able to receive a referral reward, but retirement alone does not answer the question. The AICPA's referral-fee rule is written around a member in public practice and a client for whom the member or firm performs certain services, and state boards license individuals and firms under their own rules. Whether your status is retired, inactive or active, and whether you still hold a license, AICPA membership or any link to a firm, decides which rules reach you. Ask your state board in writing before accepting anything.

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

What the AICPA Code says about referral fees

The AICPA Code of Professional Conduct contains a Commissions and Referral Fees rule (ET 1.520) and a Contingent Fees rule (ET 1.510). In broad terms, 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. Where a referral fee is permitted, it must be disclosed to the client. Read the current text on the AICPA site rather than relying on a summary.

Three points matter for retirees:

  • The rule keys on public practice. A retired member who no longer practices may fall outside the language, but the Code and its interpretations should be read for how they treat former firm affiliations.
  • Clients are tied to the firm. If your former firm still audits or reviews the company you would introduce, ask whether the rule reaches you through that relationship.
  • Disclosure is the safe habit. Even when a fee is allowed, the owner should hear about it before the introduction.

Why the state board may matter more than the Code

State rules can be stricter than the AICPA Code. The New Jersey CPA society's guidance is one example of a state treating commissions and contingent fees differently, and Florida regulates referral fees by statute, as the Florida statute on contingent fees, commissions and referral fees shows; that page is the 2017 version, so check the current text. Some states adopt the AICPA rule by reference, others write their own.

How status changes the questions

Your statusWhat to checkLikely direction to confirm
Active license, still in a firmFirm policy, attest clients, state ruleStrictest case; the firm's ethics partner decides
Retired from a firm, license still activeState board rule for active licensees, any ties to the firm's clientsActive licensees stay bound by board rules
Inactive or retired license statusWhether the board's rules still reach you, any use of the CPA titleOften fewer restrictions, confirm in writing
Lapsed license, no longer using CPA titleRepresentations you make to ownersDo not imply credentials you no longer hold
AICPA membership keptCode interpretations for members not in public practiceMember obligations may persist
Consulting or advisory role for a firmFirm engagement termsContract and firm policy may bar side fees

Each row is a question to take to the board, not an answer.

The retiree checklist

  • Write down your license status in every state where you hold one, and your AICPA membership status.
  • List the companies you would consider introducing and mark any for which your former firm still performs attest work.
  • Check whether your retirement agreement, partnership agreement or non-compete restricts outside compensation or client contact.
  • Ask your state board in writing whether the rules on commissions and referral fees apply to your status.
  • Decide how you will disclose the arrangement to the owner before you make any introduction.
  • Keep a copy of the board's reply with your partner records.

Where retirees are well placed

Retired partners still carry trust with owners, and many sit on advisory boards or run small consulting practices. The best candidates are former clients that are now larger operating businesses: 50+ full-time employees at peak (contractors excluded), years of documented history and a CFO or owner who can act as sponsor. The accountants page covers the active-practice version of this, and the list of who earns shows other partner types.

You should not use confidential client files, tax returns or workpapers to choose targets or to describe a company. Partners give basic fit information only and never export, upload or describe confidential records.

What to say to a former client

Other questions that look similar

Retirees sometimes hold other roles that raise different questions: a former MSP relationship is covered in the page on returning admin credentials, a tax debt in the federal tax lien page, and visa status in the work visa question.

How rewards work

Partners earn 25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, capped at $100,000 cumulative per referred company. The partner reward is a share of SourceX's fee and is never deducted from what the company receives. Rewards become payable only after the buyer pays and SourceX receives its fee, and no reward is guaranteed.

When not to bother

Skip it if your board says no, if your retirement agreement bars it, or if you cannot reach a decision maker at any company that fits the baseline.

Next step

Register as a partner once you have your board's reply, then use the company fit checker. The who qualifies page covers the company baseline.

  1. Step 1Share your linkSend your personal link to a company you know.
  2. Step 2Company appliesThe company applies itself at /apply.
  3. Step 3Buyer selects and paysThe buyer selects and pays for the data and SourceX receives its fee.
  4. Step 4You get your rewardYour share of SourceX fees becomes payable.

Common questions

Does the AICPA rule apply after I retire from my firm?

It depends on how the Code treats your status and whether you remain a member. The referral-fee rule is written around members in public practice and clients receiving certain services from the member or firm. Do not assume retirement ends it. Read the current Code and ask the AICPA ethics hotline or your state board.

Is a state board bound by the AICPA Code?

No. Boards write their own rules. Some adopt AICPA provisions by reference, others publish their own, and some are stricter. If you still hold a license, even an inactive one, the board's rules for that status may still reach you. Ask the board how it treats your status.

Should I disclose the reward to the owner?

Yes, as good practice and often as a rule. Tell the owner before the introduction that you may receive a reward if a deal closes, and that nothing changes what the company receives. Disclosure also protects the relationship if the owner later asks how you came to recommend SourceX.

Can I look at old client files to find candidates?

No. Do not use confidential client information, tax returns or workpapers to choose or describe companies. Pick candidates from what you know publicly or from your own current relationships, and give basic fit information only. Confidential records never come through a referral partner.

What if my former firm audits the company?

Treat that as the highest-risk case. The attest relationship is the situation the referral-fee rule is aimed at, and firm policy may bar related fees for anyone connected to the client. Get written guidance from the firm's ethics contact and your state board before saying anything to the owner.

Free resources

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

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