In Canada, a CPA may accept a referred client. For routine engagements, provincial codes (Rule 216 of the Harmonized Code, Section 35 in Quebec) permit compensation for matching, subject to safeguards, written disclosure, and client consent. For an assurance client (audit, review engagement), paying a commission to acquire the client is prohibited. Fees paid for an actual and defined service are expressly excluded from the definition of compensation under the Harmonized Code; the substance of the agreement takes precedence, and the text of your professional order is authoritative.
A firm that receives a client through a matching service quickly asks itself: Is this in compliance with the code of ethics? The short answer is yes, client referrals are permissible for a CPA in Canada, provided two conditions are met: disclosure to the client and the preservation of independence. Here is an overview, province by province, and the steps to take before signing anything.
The profession regulates the practice; it does not prohibit it. Each provincial regulatory body enforces a code of ethics that is largely harmonized across Canada: the CPA Code of Professional Conduct in Ontario and in most common-law provinces, the Code of Ethics for Chartered Professional Accountants in Quebec. CPA Canada supports the profession at the national level, but your provincial regulatory body is the authoritative source.
Three principles underpin the analysis of a referral arrangement:
The key distinction: it’s not the matching process itself that’s the problem, but rather the nature and transparency of the accompanying financial arrangement. Regulatory oversight focuses on referral fees (referral fees) hidden fees and commissions based on billed fees.
Under the harmonized code applied in Ontario and several other provinces, Rule 216 (“Commission or Compensation Arrangements”) governs the payment or receipt of compensation related to client referrals. The intent of the rule is that such an arrangement must be disclosed to the client and must not compromise the member’s objectivity. The exact wording and exceptions vary from province to province: always refer to the text published by your professional regulatory body (see sources at the end of the article).
Not all customer acquisition channels are equal from an ethical standpoint. The following table ranks common arrangements from the riskiest to the easiest to manage:
| Agreement | Financial Mechanics | Key Ethical Requirement | Risk Level |
|---|---|---|---|
| Commission as a Percentage of Billed Fees | The referrer is paid through your invoice, payment by payment | Disclosure: A Direct Threat to Independence (Incentive to Overbill) | High |
| Referral fee not disclosed | Hidden Payment Between the Referrer and the Firm | Non-compliant: Disclosure to the customer is missing | High |
| Fixed and Disclosed Referral Fee | One-time payment, separate from the engagement fees | Disclosure made; monitor for conflicts of interest | Moderate |
| Fixed-fee matching service, with no commission on fees | Cost known in advance, no markups on the customer’s bill | Simple disclosure; independence preserved | Low |
| Advertising and Organic Search Engine Optimization | No third parties are paid for matching clients | The Order’s Advertising Rules (truthfulness, no misleading comparisons) | Low |
The logic is consistent: the more the referrer’s compensation is tied to your fees, the greater the threat to your independence, and the more difficult it becomes to draft the disclosure. A fixed-cost arrangement, known in advance and separate from your billing, is the easiest to disclose and defend. Regarding the bulk purchase of leads, which follows the same framework for analysis, see Buying Accounting Leads: What to Check Before Paying.
Ontario. CPA Ontario applies the CPA Code of Professional Conduct, including provisions on commissions and referral fees. Matching is permitted for ongoing engagements, subject to safeguards, written disclosure, and client consent (Rule 216.1); it is prohibited when the payment constitutes compensation paid to obtain an audit client (Rule 216.2), regardless of disclosure. Fees paid for a specific, actual service are expressly excluded from the definition of compensation under Rule 216; however, the Order assesses the substance of the agreement.
Quebec. The Ordre des CPA du Québec enforces the Code of Ethics for Chartered Professional Accountants (RLRQ, c. C-48.1, r. 6.1, in effect since May 2024), Article 35 of which permits the payment of a referral fee to acquire a client, provided that safeguards are in place and the client is informed in writing, while Article 36 prohibits the payment of such a fee to acquire a client for assurance services. The safest approach: verify that any arrangement complies with the current text before committing to it, as the Quebec version is more restrictive than the harmonized code on certain points.
Other provinces. CPABC, CPA Alberta, and other professional bodies apply variations of the harmonized code. The principles (disclosure, independence, client’s best interests) are common; however, the thresholds, definitions of “related party,” and specific disclosure requirements vary. The professional bodies do not publish any consolidated statistics on the frequency of sanctions related to referral fees: if in doubt, your professional body’s ethics hotline is available to answer these types of questions.
Beware of the classic pitfall: extrapolating foreign rules to Canada. The regulations differ in specific ways; compare them with our analyses of referral fees according to the AICPA in the United States, the ethics of business referrals for accounting professionals in France, and the Overview of Referral Rules by Country.
This qualification process adds to the actual cost of acquiring a customer, which is often underestimated. Our benchmarks on Customer Acquisition Cost for an Accounting Firm and on Time Wasted Looking for Clients help compare each channel based on its total cost.
Analyzed using the table above, the affiliate program featured on the hub Bankeo for Accounting Firms falls into the low-risk category in the table:
In terms of volume and traceability: the network has 1,500+ registered accounting firms (Bankeo verifies that each accountant is registered with their professional association before matching them with a client), more than 15,000 requests received since 2023, a note from 4.7/5 based on 180+ Google reviews and matching often established through 48 hours. The reliability criteria applied to the network are documented in the Bankeo Trust Index. For practical questions (types of requests, sectors covered, the matching process), see the FAQ for Partner Firms and the Network News.
The question is not whether a CPA can accept a referred client, but under what conditions. As long as no commission is deducted from the fees and no one else is involved in the engagement, the CPA remains fully responsible for their work, their rates, and their independence: this is the most ethically sound scenario.
Key takeaways. Client referrals are permitted for CPAs in Canada. There are two requirements: disclosing the nature of the relationship to the client and maintaining independence. The risk centres on commissions tied to fees; a fixed cost known in advance, with no involvement in the engagement, is the simplest scenario to disclose and defend before one’s professional association.
Yes. Accepting a client referred by a matching service is permissible, provided that transparency is maintained with the client and professional independence is preserved. The sensitive issue is the financial arrangement, not the matching process itself.
Best practice is to inform the client of the nature of the relationship, ideally in the engagement letter. Disclosure is all the easier since no referral fee is charged for the engagement.
Not necessarily, but it is the most closely monitored arrangement: disclosure is required, there is a threat to independence, and it may be incompatible with certain engagements, particularly attestation engagements. Review the text of your order before committing.
No. Bankeo never charges a commission on the firm’s fees: the service is based on a fee per file, with the amount known in advance. The fees billed to the client go entirely to the firm.
The principles (transparency, independence, and the client’s best interests) are the same, but the specific provisions vary by provincial regulatory body, and Quebec has stricter rules regarding rebates and commissions. Always refer to your province’s code.
Yes. Bankeo verifies that accountants are registered with their professional association before matching them with clients. Several members of the network are CPAs registered with their provincial association. This is why we refer to them as vetted accountants.
Sources last verified: July 2026. Regulations are subject to change; the text published by your provincial regulatory body is authoritative.
By Arnaud Bertrand, CEO of Bankeo.
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