What is an attest client, and why does it decide referral fees for CPAs?
An attest client is a client for whom a CPA's firm performs an audit or review of financial statements, an examination of prospective financial information or certain compilations. The label matters because the AICPA Code bars commissions for recommending a product or service to such a client and restricts contingent fees, so screen your list before any paid introduction.
Attest client: the definition
An attest client is a client for whom you or your CPA firm performs attest work, such as an audit or review of financial statements or an examination of prospective financial information. For the fee rules in the AICPA Code, certain compilations are treated the same way. The status belongs to the client relationship across the whole firm, not to one engagement team.
That makes the term practical rather than academic for CAS, tax and advisory partners. Before you accept any compensation connected with recommending a product or service to a client, you need to know whether anyone in the firm performs attest work for that client.
Which services make a client an attest client?
Audits, reviews and examinations of prospective financial information do; tax, bookkeeping and consulting work on their own do not. Compilations sit in between.
| Service the firm provides | Attest client for the fee rules? | What to check |
|---|---|---|
| Audit of financial statements | Yes | The commission ban and contingent-fee restriction apply |
| Review of financial statements | Yes | Same as an audit |
| Examination of prospective financial information | Yes | Same as an audit |
| Compilation | Only certain compilations | Read the rule text for which ones are covered |
| Tax return preparation only | Not on that basis alone | Contingent fees on returns are limited separately; check your state |
| CAS bookkeeping, payroll and monthly close | Not on that basis alone | Confirm no other office performs attest work for the client |
| Advisory, valuation or consulting | Not on that basis alone | Run the same firm-wide check |
Is a compilation an attest service? Not in the assurance sense, because a compilation provides no assurance on the statements. The fee rules nonetheless name certain compilations, so the label can still attach. Read the exact wording in the Code and your state rules, and ask your ethics partner, before treating a compilation client as unrestricted.
Attest client vs non-attest client and related terms
| Term | What it means | Why it matters for fees |
|---|---|---|
| Attest client | A client receiving audit, review, examination or covered compilation work from the firm | Commissions are barred and contingent fees restricted |
| Non-attest client | A client receiving only tax, bookkeeping, advisory or other nonattest services | Commissions and referral fees may be permitted with disclosure, subject to state rules |
| Attest engagement | The engagement itself, performed under auditing, review or attestation standards | Requires independence from the client |
| Nonattest service | Work such as tax, CAS or consulting | Allowed for an attest client only within independence limits |
| Restricted entity list | A firm's internal list of clients and affiliates it must stay independent of | The quickest way to see attest relationships across offices |
Why attest status decides referral compensation
The AICPA Code ties its fee restrictions to attest work. Its Commissions and Referral Fees Rule (ET 1.520) says a member in public practice may not accept a commission for recommending a product or service to a client when the member or the member's firm also performs an audit, review, certain compilations or an examination of prospective financial information for that client. Where a commission or referral fee is permitted, it must be disclosed to the client.
The Contingent Fees Rule follows the same line: a fee that depends on reaching a specific result may not be charged to a client for whom the firm performs that attest work. Two further layers can apply. If your firm audits public companies, the SEC's auditor-independence rules on contingent fees are a separate regime to check. And state boards can be stricter than the AICPA Code, as the New Jersey Society of CPAs' summary of its state rules shows.
Whether a reward from a business such as SourceX counts as a commission or a referral fee under the Code is a classification question for your ethics partner or state board. Either way, attest status is the first gate.
This is general information, not legal, tax or financial advice. Confirm with your own counsel, tax adviser or professional body before acting.
The three-list screen before you introduce a client
Run three checks, in order, before anyone mentions an introduction to a client.
- Attest list. Pull every client for whom any office of the firm performs audit, review, examination or compilation work. Set those clients aside unless your ethics partner clears them.
- Affiliate list. Check the firm's restricted entity list for parents, subsidiaries and sister companies of attest clients. A non-attest subsidiary of an audited parent needs a closer look.
- Disclosure file. For the non-attest clients that remain, prepare the written disclosure your firm and state require, and keep a copy with the engagement file.
Then check business fit. SourceX looks for US companies with 50+ full-time employees at peak (contractors excluded), several years of documented operations, records spread across many systems, the right to license those records and an owner or executive able to sponsor the application. The company fit checker gives a quick, non-binding first read, and who qualifies sets out the full baseline.
Illustrative: a fictional regional firm runs CAS for a 140-person engineering company and also issues a review report on its statements for the company's bank. The CAS manager notices a decade of project records and wants to suggest a data license. Because the firm performs a review, the company is an attest client, so the question goes to the firm's ethics partner before anyone speaks to the owner.
What it means for a SourceX introduction
For a client that clears the screen, the partner's role is narrow: make the introduction and share basic fit information. The company handles its data inventory, rights review, pricing and delivery directly with SourceX, and nothing is shared without a signed agreement and the company's authorization.
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, payable only after the buyer pays and SourceX receives its fee. The reward comes out of SourceX's fee and is never deducted from the client's proceeds, but that does not change how the AICPA Code or your state board classifies it. If your firm decides it cannot accept compensation for a client, that client can still apply directly at sourcex.si/apply.
Two related terms are worth knowing: client accounting services, where attest and nonattest work often meet in the same client, and the fractional CFO model, where a CPA may sit inside the client's finance team.
Next step
Run the three-list screen on your client book this month. For non-attest clients that pass, register as a partner and make the introduction with written disclosure in place. The referral overview for accountants covers the rest of the workflow.
- 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 tax-only client an attest client?
No. A client for whom your firm only prepares tax returns is not an attest client on that basis alone. Check that no other office of the firm audits, reviews or compiles the client's statements, and remember that contingent fees for preparing returns are limited separately under professional and state rules. A tax-only client can still require written disclosure of any commission or referral fee you accept.
Does an audit by another office of my firm make my client an attest client?
Yes. The fee rules look at whether the member or the member's firm performs attest work for the client, not at which team or office does it. Firms usually track this with a firm-wide client list or restricted entity list. Check it before you introduce anyone, because a CAS or advisory partner may not know about an audit run elsewhere in the firm.
Can I accept a referral reward for a non-attest client without telling the client?
No. Under the AICPA Code, permitted commissions and referral fees must be disclosed to the client, and many state boards set their own written disclosure requirements. Disclose before the introduction, explain who pays you and how the amount is set, and keep a copy. In SourceX's case the reward comes out of SourceX's fee, which is worth stating in the disclosure.
Is a former audit client still an attest client?
It may be for a time. The restriction can reach beyond the engagement itself, depending on the periods the rule text covers, so a client you audited or reviewed recently may still be restricted. Read the exact wording, check your firm's independence records and ask your ethics partner or state board before treating a former attest client as clear for any paid introduction.
Do state boards use the same attest client rules as the AICPA?
Not always. Many states follow the AICPA Code's approach, but some set their own rules on commissions, referral fees and contingent fees in statute or board regulation, and some are stricter. Your licensing state's board of accountancy governs, so check its current rules, and if you hold licenses in more than one state, check each of them.
Related pages
- What is client accounting services (CAS), and what does a CAS team do?
- What is a fractional CFO, and what should one check before introducing a client?
- Referral opportunities for accountants and bookkeeping firms
- Check Company Fit for Data Licensing
- Which US businesses are a fit for a SourceX data licensing introduction
Free resources
- Business valuation calculator — Enterprise and equity value from EBITDA, your multiple, cash and debt.
- Portfolio data opportunity scanner — Screen several companies in one session.
- Working capital calculator — Net working capital, current ratio and quick ratio.
- All free tools · MCP resource center
By SourceX Partnerships Team · Published 2026-10-09 · Updated 2026-10-09
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