Referral fee policy template for CPA, CAS and advisory firms

A CPA firm referral fee policy sets out, once and in writing, who may accept third-party referral compensation, which clients are excluded (attest clients above all), how clients are told before any introduction, who approves each program and what records are kept. The template below lets a firm approve a program such as SourceX's once instead of case by case.

When does a CPA or advisory firm need a referral fee policy?

A firm needs a written referral fee policy as soon as anyone in it could be paid by a provider a client is introduced to. Without one, every introduction becomes a fresh ethics question answered by whoever happens to be asked, and the people making introductions from CAS or advisory often cannot see which clients the audit side serves.

The professional rules make that visibility essential. ET 1.520, the commissions and referral fees rule in the AICPA Code of Professional Conduct, bars a CPA in public practice from taking a commission for recommending a product or service to any client for whom the CPA or the firm performs an audit or review, certain compilation engagements, or an examination of prospective financial information. Where a commission or referral fee is allowed, the client has to be told about it. The rule text is in the AICPA Code as published by the Minnesota Board of Accountancy; check the AICPA's online Code for the current version.

States layer their own rules on top. Kansas, for example, requires CPAs and firms to comply with the AICPA Code's provisions on commissions and referral fees, including its interpretations, while a New Jersey Society of CPAs resource on commissions and contingent fees illustrates that a state's rules can depart from the Code and go further than it. For background on how these arrangements are structured, see what a referral fee agreement is.

A policy turns those rules into firm practice: one decision about which programs are acceptable, one conflict check, one disclosure standard and one log.

Person in the firmRisk without a policyWhat the policy settles
CAS or outsourced accounting managerIntroduces a client the audit team also servesA mandatory attest-client check before any introduction
Tax partnerTreats a referral share as personal incomeWhether compensation belongs to the firm or the individual
Staff fractional CFO or controllerMentions a provider without telling the client about compensationWritten disclosure before the introduction
Marketing or business developmentPromotes a provider in a newsletter without noting the connectionA rule for public mentions and their disclosure
Managing partnerApproves cases one by one with no recordAn approved-program list and an annual review

The referral compensation policy template

Copy the sections below into your firm's policy format. Replace each item in braces, delete options that do not apply, and have your ethics counsel or state society review the final text.

Section 1: Purpose and scope

Section 2: Definitions

Section 3: Who may accept referral compensation

Section 4: Clients excluded from compensated introductions

Section 5: Checks before any introduction

Section 6: Disclosure to the client

Section 7: Approval and conflicts

Section 8: Compensation, tax forms and records

Section 9: Review and breaches

The disclosure wording referred to in Section 6 is ready to adapt in the engagement letter clause for third-party referral compensation.

Schedule A entry: approving the SourceX partner program once

The template is built so a program can be approved once and then used under the standard checks. A completed Schedule A row for SourceX might read:

FieldEntry for SourceX
ProgramSourceX Partner Program, a referral program for data licensing introductions
What the firm doesIntroduces a client and shares basic fit information; never exports, uploads or describes client records
Eligible clientsUS companies that reached 50+ full-time employees at peak (contractors excluded), with a multi-year documented operating history, that hold the rights to license their own records, and with an executive able to sponsor the decision
Compensation basis25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, capped at $100,000 per referred company
When payableOnly after the buyer pays and SourceX receives its fee; an introduction, meeting or signed agreement alone triggers nothing
Effect on the clientPaid out of SourceX's fee and never deducted from what the client receives
Excluded clientsAttest clients and their affiliates, plus any client excluded under Section 4
Governing termsThe signed partner agreement and the published program terms
Approved by and date{ethics_partner}, {date}

No reward is guaranteed: a referred company may not qualify, may decide not to license, or a deal may not close.

Contingent fees and SEC independence: two checks beyond ET 1.520

Because the SourceX reward depends on a deal closing and being paid, some ethics partners also review it against the contingent fees rule (ET 1.510). As the NYSSCPA explains, the AICPA Code treats a contingent fee as one whose amount depends on attaining a specific result, and prohibits members from performing services for a contingent fee where the firm also audits or reviews that client's financial statements, performs certain compilations for it, or examines its prospective financial information. For this policy the practical effect is the same exclusion: no compensated introductions of attest clients.

Firms that audit SEC registrants face a separate regime. SEC auditor-independence rules on contingent fees sit apart from the AICPA Code, as SEC staff correspondence with the AICPA ethics committee shows, so those firms should run the check under both.

This is general information, not legal, tax or financial advice. Confirm with your own counsel, state board or professional body before adopting the policy.

How to adapt the template to your firm

Firm typeKeepChange
CAS-only firm with no attest practiceDisclosure, approval and log sectionsReduce Section 4 to a check on whether any network or affiliated firm performs attest services for the client
Multi-service CPA firmEvery sectionName an owner for the firm-wide attest-client list and set a turnaround time for checks
Firm in an alternative practice structureEvery sectionMap which entity holds the attest practice and which holds advisory; see private equity owned CPA firms and the push for advisory revenue
Fractional CFO firm with no CPA licenseesDisclosure, approval and log sectionsReplace the AICPA references with your consulting agreements and clients' conflict-of-interest policies
Solo practitionerDisclosure and log sectionsName yourself as approver and diarize the annual review

Record-keeping and tax paperwork

The referral log is what makes the policy defensible. Complete one row per introduction before the introduction is made, then update it when compensation arrives or the client declines.

Tax paperwork follows the payee. If the firm is the registered partner, the firm supplies its own taxpayer details; a US payer will typically ask for Form W-9, which provides a correct taxpayer identification number to a person who must file an information return reporting amounts paid. Register the partner account in the same name that will receive and report the income, and confirm the treatment with your tax adviser.

What the policy should never permit

  • Sharing client files, exports, screenshots or descriptions of confidential records with any program
  • Telling a client what a license might be worth or when money will arrive
  • Quoting reward amounts to clients instead of the published formula
  • Accepting compensation for an attest client, including after the introduction was made
  • Personal acceptance of compensation that the policy routes to the firm
  • Introductions the client has not asked for or agreed to

Next step

Adopt the policy, add SourceX to Schedule A, and screen each candidate client against the baseline using the company fit checker before sending your disclosure. Then register as a partner in the name your policy specifies and make the first introduction.

  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

Should referral compensation go to the firm or to the individual who made the introduction?

It is a firm decision, shaped by your partnership or operating agreement, compensation plan and state rules. Routing it to the firm keeps incentives out of individual advice and simplifies records and tax reporting. If individuals may accept it, the policy should require written approval and the same disclosure and attest checks as any firm-level referral.

Is disclosure to the client enough, or does the client have to consent?

The AICPA rule requires permitted commissions and referral fees to be disclosed to the client, and some states set their own requirements. Many firms go further and ask for a written acknowledgment before the introduction, because it proves the client knew and chose to proceed. Check your state board's rule and decide which standard your policy adopts.

What happens if an introduced client later becomes an attest client?

The policy should answer this before it happens. A sensible approach is to require the engagement partner to check any new attest engagement against the referral log, then have the ethics partner decide, with counsel where needed, whether compensation can still be accepted or must be declined. Document the decision either way.

Do fractional CFO firms without CPA licensees need this policy?

An accountancy rule may not apply to them, but consulting agreements, client conflict-of-interest policies and agency contracts often restrict outside compensation, and clients expect to know when an adviser is paid by someone else. A short version of the policy that keeps the disclosure, approval and log sections protects both the firm and the relationship.

How often should a referral fee policy be reviewed?

Review it at least once a year, ideally after busy season when engagement letters are renewed, and whenever your state board, the AICPA Code or an approved program's published terms change. Use the review to compare the referral log with the attest-client list, retire programs nobody uses and confirm the disclosure wording still matches current terms.

Can staff mention an approved program in a newsletter or on LinkedIn?

The policy can allow it for approved programs only, with a clear disclosure of the firm's financial connection placed next to the recommendation. Public posts should describe the program factually, avoid any promise about what clients will receive and never name a client without that client's written permission.

Free resources

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

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