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Receiving a referred client is permitted at Canada in France and the United States. However, the remuneration for the introduction differs: authorized for standard mandates in Canada with written disclosure and client consent, permitted with written disclosure in the United States (AICPA ET §1.520), prohibited in France for the equivalent accounting professional (Article 24, Ordinance of 1945). In an assurance engagement, the Canada Quebec prohibits paying a commission to acquire a client; in the United States, payment remains permitted with written disclosure. Fees paid for a specific and defined service are not treated as a commission under the Canadian Harmonized Code.
An accounting firm that accepts a client referred by a colleague, a financial institution, or a referral platform is not committing any wrongdoing: the practice is permitted. Canada In France and the United States, the real ethical question is that of compensation for this referral. Referral fees, commissions, and business referral fees: each system draws its own line, and crossing it exposes the firm to disciplinary action. Here, with supporting legal texts, is what the three frameworks actually allow, and what your firm should verify before signing a business referral agreement.
The French accounting profession has over 220,000 members according to CPA Canada (2025 data). It is governed by provincial professional orders: each department applies its own code of ethics, but these codes share a common structure resulting from the unification of the profession. For most firms, the key documents are the Code of Ethics of the Ordre des CPA du Québec (approximately 41,000 members according to the Order) and the Code of Professional Conduct of CPA Ontario , the largest provincial order in the country.
A CPA may accept a client referred by a third party and may, in some cases, pay or receive compensation related to that referral. Two safeguards systematically govern the practice: disclosure and independence.
When a commission or referral fee is involved, the client must be informed. They must understand that an economic relationship exists between the accountant and the person who referred them, so they can judge for themselves the objectivity of the advice they receive. Verbal and delayed disclosure protects neither the client nor the firm: professional bodies expect clear information, provided before the engagement is accepted and kept on file.
No referral agreement can compromise the objectivity, integrity, or professional judgment of a CPA. The codes also distinguish between two realities: commissions, meaning a benefit paid because a client has been obtained or referred, and fees paid for a specific and defined service, the amount of which is known in advance (qualification of requests, referrals, file documentation, and administrative preparation up to the engagement letter). In Quebec, the CPA Code of Ethics (section 35) allows for the payment of a commission to obtain a client, provided that safeguards are implemented and the client is informed in writing. The rule becomes significantly stricter when the engagement requires independence: for assurance services (audits, review engagements), section 36 prohibits paying a commission to obtain the client, and no disclosure renders the arrangement acceptable. The harmonized code of the other provinces (rule 216) follows the same logic, and its definition of compensation expressly excludes fees paid for services rendered.
In practice, the Canadian framework tolerates paid referrals for routine engagements (bookkeeping, taxes, consulting), provided they are disclosed in writing and the client's consent is obtained, but it prohibits paying a commission for obtaining a client for certification. Fees paid for a specific and defined referral service, unrelated to the fees charged to the client, are not treated as a commission under the Harmonized Code; however, professional bodies value the substance of an agreement over its labeling. A detailed, body-by-body analysis of the Canadian regime is presented in our article on client referrals and the CPA Code in Canada .
The key takeaway: professional ethics do not prohibit paid referrals, but they regulate the nature of the payment and the type of engagement. A commission paid to acquire a client requires written disclosure and the client's consent for ongoing engagements, and becomes prohibited as soon as a certification engagement is involved. Canada And in Quebec, fees paid for actual matchmaking services (screening, qualification, documentation, file preparation) are not treated the same way by the regulations. In all cases, the substance of the agreement takes precedence over its labeling, and the text of your professional order is authoritative.
In France, the equivalent professional falls under the jurisdiction of the Order of Chartered Accountants , which has approximately 21,000 registered professionals according to data published by the Order. The French system is one of the strictest in the world regarding fees, and this contrasts sharply with the Canadian approach.
The foundational text is Ordinance No. 45-2138 of September 19, 1945, available on Légifrance . Article 24 stipulates that this professional's fees are exclusive of any other remuneration, particularly any indirect remuneration paid by a third party. In practical terms, this professional can only be paid by their client for the work actually performed. It is forbidden to receive a commission from a third party in exchange for a client referral, just as it is forbidden to pay such a commission to acquire clients.
The framework has nevertheless evolved: Decree No. 2012-432 of March 30, 2012, authorized solicitation, long prohibited, subject to respect for the dignity of the profession and an obligation of discretion. A French professional can therefore prospect and communicate, without circumventing the prohibition on commission-based fees. The details of the French system are analyzed in our article on commercial activity and the ethics of the French accounting profession.
In the United States, the national reference is the AICPA Code of Professional Conduct, whose section ET §1.520 "Commissions and Referral Fees" specifically addresses this issue. The American system is more permissive than the French system, but subject to conditions.
For Canadian firms serving cross-border clients, our analysis of the AICPA benchmarking criteria details the rule and its state variants.
| Criterion | Canada | France | United States | |
|---|---|---|---|
| Accept a referred client | Permit | | Permit | | Permit | |
| Compensation for the introduction | License for current mandates, with disclosure | Prohibited (commission based on fees) | Permission without certification, with disclosure to the client |
| Form of disclosure | Mandatory (details vary according to provincial regulations) | Not applicable (prohibited practice) | Mandatory (ET §1.520); written form is the norm, required by several States; |
| Assignment of assurance (audit, review) | Commission prohibited (independence required); | Prohibited, like all commissions | Referral fees and commissions are prohibited. |
| Solicitation and solicitation | Permits, governed by state codes; | Authorized since the decree of March 30, 2012, with reservations regarding dignity | Licenses, overseen by the State Boards |
| Reference text | Provincial codes of ethics (CPA Ontario, Ordre des CPA du Québec) | Ordinance No. 45-2138 of 1945, Article 24 | AICPA Code of Professional Conduct, ET §1.520 |
| Local variations | | Harmonized interprovincial codes, possible nuances | Single national system; | 50 states; some stricter than the AICPA |
This table summarizes the regulations; it is not a substitute for reading official documents or seeking advice from an authorized professional in the relevant jurisdiction. Codes of ethics are regularly updated.
A common confusion muddles the debate on business referrals: that between a commission on fees and a price paid for a service. The two have neither the same legal nature nor the same ethical treatment.
A commission, as defined or prohibited depending on the country, is a sum indexed to the fees that the accountant charges their client, generally expressed as a percentage of the invoice. This form raises three problems:
It is precisely this mechanism that France forbids, that the AICPA prohibits in attestation missions and that French professional bodies strictly regulate.
Conversely, a fixed price paid for a genuine lead generation service compensates for an identifiable service (need assessment, prospect introduction) at a predetermined amount, independent of the fees the accountant will subsequently bill. It creates neither the dependency nor the conflict of interest targeted by commission-based fee prohibitions: the accountant retains all of their fees and freely sets their rates with their client.
The boundary is not a matter of semantics: it determines compliance. The same financial flow can be prohibited if it is classified as a commission on fees, and eligible if it remunerates, at a fixed price, a referral service actually rendered. The structure of a business referral scheme is therefore as important as its mere existence.
Key points to remember: In all three countries, accepting a referred client is permitted. Compensation for the referral is allowed, with disclosure to Canada And in the United States (where written agreements are the American standard), commissions are prohibited in France in the form of fees. In attestation engagements, all commissions are prohibited everywhere. The structure of the payment flow—a fixed amount for a service or a percentage of fees—determines compliance.
Yes, in all three countries. Receiving a client referred by a colleague, platform, or partner is a common and accepted practice. The restrictions concern the potential remuneration for this referral and respect for independence, not the client's acceptance.
At Canada And in the United States, yes, as soon as a reference fee or commission is involved. In the United States, the AICPA Code (ET §1.520) mandates disclosure; written disclosure is the professional standard, and several states expressly require it. In France, the issue is not framed in the same way: commissions on fees for this professional are prohibited in principle.
Article 24 of the 1945 ordinance stipulates that this professional's fees are exclusive of any indirect remuneration from a third party. This exclusivity, designed to guarantee independence, prohibits the very mechanism of commissions, whereas the Canadian and American systems permit it under certain conditions.
An attestation mission (audit, review, examination) requires enhanced independence. Canada As in the United States, commission or referral fee arrangements become prohibited for the client concerned, because they would compromise the objectivity of the accountant who guarantees the financial information.
Not necessarily. A fixed amount, established in advance and independent of the fees charged to the client, compensates for a matchmaking service and does not constitute a commission indexed to fees. The classification depends on the actual structure of the arrangement and must be verified against the applicable code.
At Canada , with CPA Canada and the relevant state's regulations. In France, these can be found on Légifrance and with the French Institute of Chartered Accountants (Ordre des experts-comptables). In the United States, they can be found in the AICPA Code of Professional Conduct and with the State Board of the state where the practice is held. Direct links are provided in the Sources section below.
Is your firm wondering how these rules fit with a matching platform? Frequently asked questions from partner firms answer this point by point.
Codes of ethics are evolving: professional bodies' positions, disciplinary decisions, and reforms to the regulations. To stay up-to-date, follow the latest news for accountants .
Bankeo connects entrepreneurs with a network of 1,500+ registered companies. Canada With over 15,000 applications received since 2023, matchmaking often completed within 48 hours, and a 4.7/5 rating based on over 180 Google reviews, this channel brings qualified clients to an accounting firm without the need for prospecting. The process is detailed on the "How it works" page , and the entire program is available on the Accountants Hub .
This page documents the ethical guidelines applicable to the commercial contributions of accountants; it does not constitute legal advice. By Arnaud Bertrand, CEO of Bankeo.
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