Customer referencing and CPA code at Canada

A firm that receives a client through a referral service quickly asks itself: is this ethical? Short answer: yes, client referrals are eligible for a CPA (Customer Performance Appraisal). Canada This is subject to two conditions: disclosure to the client and preservation of independence. Here is the framework, province by province, and the steps to take before signing anything.

What CPA codes say about customer referrals

The profession regulates the practice, it does not prohibit it. Each provincial professional order applies a code of ethics that is largely harmonized across Canada: the CPA Code of Professional Conduct in Ontario and most common law provinces, and the Code of Ethics of Chartered Professional Accountants in Quebec. CPA Canada supports the profession nationally, but your provincial professional order is the authoritative body.

Three principles structure the analysis of a referencing agreement:

• Transparency towards the client : the client must be able to understand how the relationship was established and whether a financial benefit flows between the referrer and the firm.
• Independence and objectivity : no arrangement should influence the member's professional judgment or their pricing.
• The client's interest comes first : the mission, its scope and its quality take precedence over the mechanics of making connections.

The crucial distinction: it's not the introduction itself that's the problem, but rather the nature and transparency of the accompanying financial arrangement. Orders should be vigilant regarding hidden referral fees and commissions indexed to the fees charged.

Rule 216 of the Harmonized Code, anchor point

In the harmonized code applied in Ontario and several other provinces, Rule 216 (“Commission or compensation arrangements”) governs the payment or receipt of remuneration 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 one department to another; always refer to the text published by your professional order (see sources at the end of this article).

Commission, referral fee, matchmaking: where is the risk line drawn?

Not all acquisition channels are equal from an ethical standpoint. The following table ranks common arrangements from riskiest to easiest to manage:

Arrangement |	Financial mechanics	Primary ethical requirement	Risk level
Commission as a percentage of the fees charged	The broker is paid on your invoice, mandate after mandate.	Disclosure, plus direct threat to independence (incentive to overbill);	High
Reference fee not disclosed	Hidden payment between the contributor and the firm	Non-compliant: disclosure to the client is missing	High
Fixed and disclosed reference fee	One-time amount, separate from mission fees	Disclosure made; monitor for conflict of interest;	Moderate
Fixed-cost matchmaking service, with no commission on fees.	Cost known in advance, no charge on the customer's bill	Simple disclosure; independence preserved;	Low
Advertising and SEO	No third party is paid for the matchmaking process.	Rules for advertising the order (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 their independence, and the more difficult disclosure becomes. A fixed-cost arrangement, known in advance and separate from your billing, is the easiest scenario to disclose and defend. Regarding the purchase of leads in bulk, which follows the same analytical framework, see "Buying Accounting Leads: What to Check Before Paying ."

Three questions to ask before accepting a referred client

1. Who pays what, and indexed to what? If the answer contains "a percentage of your fees", the ethical risk increases a notch.
2. What should I disclose to the client, and when? If the disclosure is difficult to formulate in an honest sentence, the arrangement is probably too complex.
3. Who controls the mission? If the client imposes the scope, deadlines or rates, your independence is already compromised.

Province by province: same principles, different texts;

Ontario. CPA Ontario applique le CPA Code of Professional Conduct, incluant les dispositions sur les commissions et les honoraires de référence. La mise en relation est admissible pour les mandats courants, sous réserve de mesures de sauvegarde, d’une divulgation écrite et du consentement du client (règle 216.1) ; elle est interdite lorsque le paiement constitue une compensation versée pour obtenir un client de certification (règle 216.2), peu importe la divulgation. Les honoraires payés pour un service réel et défini sont expressément exclus de la définition de compensation de la règle 216 ; l’ordre apprécie toutefois la substance de l’entente.

Québec. L’Ordre des CPA du Québec applique le Code de déontologie des comptables professionnels agréés (RLRQ, c. C-48.1, r. 6.1, en vigueur depuis mai 2024), dont l’article 35 permet de verser une commission pour obtenir un client à condition d’appliquer des mesures de sauvegarde et d’informer le client par écrit, et dont l’article 36 interdit d’en verser une pour obtenir un client de services de certification. Le réflexe sûr : valider tout arrangement contre le texte en vigueur avant de s’engager, la rédaction québécoise étant plus restrictive que le code harmonisé sur certains points.

Other provinces. CPABC, CPA Alberta, and other professional bodies apply variations of the harmonized code. The principles (disclosure, independence, client interest) are common; the thresholds, definitions of "related party," and exact disclosure procedures vary. No consolidated statistics on the frequency of sanctions related to referral fees are published by the professional bodies: if you have any doubts, your professional body's ethics hotline is available to answer these types of questions.

Beware of the classic trap: extrapolating rules foreign to the Canada The regimes differ on specific points; compare with our analyses of the references according to the AICPA in the United States, the ethics of business referral for chartered accountants in France and the overview of business referral rules by country .

Compliance checklist before signing a referencing agreement

• Identify the applicable text : the code of your provincial order, not a second-hand summary.
• Clearly define the arrangement in writing : who pays, how much, when, and what the payment is based on. Demand a fixed cost known in advance, never a percentage of your fees.
• Anticipate disclosure from the engagement letter : a clear sentence on how the relationship was established and on the existence or not of a financial benefit.
• Document : keep the agreement, the disclosure, and its date on file. In case of an audit, this will be your proof.
• Reassess independence at each engagement : an acceptable arrangement for bookkeeping may become problematic for an assurance engagement.
• Monitor for changes : a service that is "initially free" and then shifts to a percentage-based commission alters the ethical nature of the arrangement. Review the terms and conditions each time the fee structure changes.

This qualification work adds to the true cost of acquiring a client, which is often underestimated. Our data on the cost of acquiring a client for an accounting firm and on the time wasted searching for clients helps to compare each channel at its full cost.

Where does the Bankeo model fit into this context?

Analyzed using the grid above, the partner program presented on the Bankeo hub for accounting firms falls into the low-risk category of the table:

• No commission on your fees. The service is based on a fixed fee per completed case, known in advance and never indexed to what you charge your client. Your rate remains entirely yours, and your fees are yours alone.
• You have no involvement in the project. Bankeo connects you with the client and then withdraws. Scope, deliverables, rates, professional judgment: everything remains under your control. Details are described on the partner program's operating page.
• A simple revelation. The situation to explain to the client can be summed up in one sentence: the introduction is made through a matching service which does not take anything from the fees for the mission.

In terms of volume and traceability: the network boasts over 1,500 verified accountants (Bankeo verifies each accountant's registration with their professional body before any match), more than 15,000 requests received since 2023 , a 4.7/5 rating based on over 180 Google reviews , and matching often completed within 48 hours . The reliability criteria applied to the network are documented in the Bankeo Index . For practical questions (types of requests, sectors covered, matching process), consult the FAQs of partner firms and the network's news section .

La question n'est pas de savoir si un CPA peut recevoir un client référé, mais à quelles conditions. Dès qu'aucune commission n'est prélevée sur les honoraires et que personne n'intervient dans la mission, le CPA reste pleinement responsable de son travail, de ses tarifs et de son indépendance : c'est le cas de figure le plus confortable sur le plan déontologique.

Key takeaway: Customer referrals are eligible for CPA at Canada Two requirements: to disclose the nature of the relationship to the client and to preserve one's independence. The risk lies in commissions indexed to fees; a fixed cost known in advance, without intervention in the engagement, is the simplest scenario to disclose and defend before one's professional body.

Frequently asked questions

Can a French CPA accept a client referred by a matchmaking service?

Yes. Accepting a client referred by a matchmaking service is permissible, provided there is transparency towards the client and professional independence is maintained. The sensitive issue is the financial arrangement, not the matchmaking itself.

Should you disclose to the client that you were put in contact by a third party?

Best practice is to inform the client of the nature of the relationship, ideally in the engagement letter. Disclosure is all the simpler since no referral fee is charged on the engagement.

Is a commission based on a percentage of fees prohibited?

Not necessarily, but it's the most closely monitored arrangement: disclosure is required, independence is threatened, and there may be incompatibility with certain engagements, particularly certification. Check the wording of your order before committing.

Does Bankeo charge a commission on the fees?

No. Bankeo never charges a commission on the firm's fees: the service is based on a fee per completed case, the amount of which is known in advance. The fees charged to the client go entirely to the firm.

Are the rules the same in all states?

The principles (transparency, independence, client interest) are common, but the specific provisions vary by province, and Quebec is more restrictive regarding rebates and commissions. Always refer to your province's code.

Are the accountants in the Bankeo network audited?

Yes. Bankeo verifies accountants' registration with their professional order before any connection is made. Several members of the network are CPAs registered with their provincial order. This is what allows us to refer to them as verified accountants.

Sources

• CPA Canada , national portal for the profession (standards and resources).
• CPA Ontario , CPA Code of Professional Conduct (200 series, including rule 216 on commissions and compensation arrangements).
• Quebec CPA Order , ethical framework for the profession.
• Code de déontologie des comptables professionnels agréés, RLRQ, c. C-48.1, r. 6.1 (LégisQuébec, texte officiel).
• CPABC , CPA Code of Professional Conduct (application of the harmonized code outside Ontario).

Last source verification: July 2026. Codes evolve; the text published by your national order is authoritative.

Par Arnaud Bertrand, CEO Bankeo.

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