Receiving a referred client is permitted in Canada, France, and the United States. However, the rules regarding compensation for matching services differ: permitted for routine engagements 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, 1945 Ordinance). In attestation engagements, Canada and Quebec prohibit the payment of a commission to secure a client; in the United States, such payments remain permitted with written disclosure. Fees paid for an actual 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 matching platform is not committing any wrongdoing: this practice is permitted in Canada, France, and the United States. The real ethical issue concerns the compensation for such a matching service. Whether it’s called a referral fee, commission, or referral bonus, each regulatory framework sets its own boundaries, and crossing them exposes the firm to disciplinary sanctions. Here, backed by supporting legal texts, is what the three regulatory frameworks actually permit, and what your firm must verify before signing a client referral agreement.
The Canadian accounting profession has more than 220,000 members, according to CPA Canada (2025 data). The profession is regulated by provincial bodies: each province applies its own code of ethics, but these codes share a common framework resulting from the unification of the profession. For most firms, the governing 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, in certain cases, may pay or receive compensation related to that referral. Two safeguards consistently govern this practice: disclosure and independence.
When a referral commission or fee is involved, the client must be informed. The client must be able to understand that a financial relationship exists between the accountant and the person who referred them, so that they can assess for themselves the objectivity of the advice they receive. A verbal or belated disclosure protects neither the client nor the firm: the regulations require clear information to be provided before the engagement is accepted and to be kept on file.
No referral agreement may compromise a CPA’s objectivity, integrity, or professional judgment. The codes distinguish between two types of compensation: commissions, i.e., a benefit paid because a client was acquired or referred, and fees paid for a specific, defined service, with an amount known in advance (qualification of requests, referral, case documentation, and administrative preparation up to the engagement letter). In Quebec, the CPA Code of Ethics (Section 35) permits the payment of a commission to acquire a client, provided that safeguards are in place and the client is informed in writing. The rule becomes significantly stricter when the engagement requires independence: for assurance services (audit, review engagement), Section 36 prohibits paying a commission to secure such a client, and no disclosure can make 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, Canadian regulations permit paid business referrals for routine engagements (bookkeeping, taxes, consulting), provided they are disclosed in writing and the client’s consent is obtained; however, they prohibit paying a commission to secure an audit client. Fees paid for a specific, defined matching service, unrelated to the fees billed to the client, are not treated as a commission under the harmonized code; however, the professional bodies assess the substance of an agreement rather than its label. A detailed analysis of the Canadian regime, order by order, is presented in Our article on client referrals and the CPA Code in Canada.
Key Takeaways: Professional ethics do not prohibit paid matching; rather, they govern the nature of the payment and the type of engagement. A commission paid to secure a client requires written disclosure and the client’s consent for routine engagements, and is prohibited as soon as an attestation engagement is involved in Canada and Quebec, whereas fees paid for an actual matching service (screening, qualification, documentation, and file preparation) are not subject to the same regulatory provisions. In all cases, the substance of the agreement takes precedence over its label, and the text of your professional association’s regulations is authoritative.
In France, the equivalent professional falls under the jurisdiction of the Order of 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 contrast sheds light on the Canadian approach.
The founding document is Order No. 45-2138 of September 19, 1945, available at Légifrance. Article 24 stipulates that this professional’s fees are exclusive of any other compensation, including any indirect compensation paid by a third party. In practice, this professional may only be compensated by their client for work actually performed. Receiving a commission from a third party in exchange for referring clients is prohibited, as is paying such a commission to obtain clients.
The regulatory framework has, however, evolved: Decree No. 2012-432 of March 30, 2012, authorized client solicitation, which had long been prohibited, subject to respect for the dignity of the profession and an obligation of discretion. A French professional may therefore solicit clients and communicate with them without circumventing the ban on commissions based on fees. The details of the French system are analyzed in our article on client referrals and the code of ethics of the French accounting profession.
In the United States, the national standard is the Code of Professional Conduct of the AICPA, specifically Section ET §1.520, “Commissions and Referral Fees,” which addresses this issue. The U.S. system is more permissive than the French system, but it is subject to certain conditions.
For Canadian firms serving cross-border clients, our analysis of referral fees based on AICPA guidelines details the rules and their state-specific variations.
| Criteria | Canada | France | United States |
|---|---|---|---|
| Accepting a Referred Client | Licenses | Licenses | Licenses |
| Matching Fees | Permitted for routine engagements, with disclosure | Prohibited (commissions on fees) | Permitted without certification, provided the client is informed |
| Form of Disclosure | Required (terms and conditions subject to provincial regulations) | Not applicable (practice prohibited) | Mandatory (ET §1.520); written records are the norm and are required by several states |
| Attestation Engagements (Audit, Review) | Commissions Prohibited (Independence Required) | Prohibited, like any form of commission | Prohibited Referral Fees and Commissions |
| Cold Calling and Solicitation | Licenses, governed by provincial codes | Authorized since the decree of March 30, 2012, subject to professional integrity | Licensed and regulated by state boards |
| Reference Text | Provincial Codes of Ethics (CPA Ontario, Ordre des CPA du Québec) | Ordinance No. 45-2138 of 1945, Section 24 | AICPA Code of Professional Conduct, ET §1.520 |
| Local Variations | Harmonized codes across provinces; possible nuances | Single National System | 50 states; some are stricter than the AICPA |
This table summarizes the regulations; it is not a substitute for reading the official texts or seeking the advice of a vetted professional in the relevant jurisdiction. Codes of ethics are updated regularly.
A common point of confusion clouds the debate on business referrals: the distinction between a commission on fees and a fee paid for a service. The two do not have the same legal nature or the same ethical treatment.
A commission, which may be regulated or prohibited depending on the country, is an amount tied to the fees that an accountant charges a client, generally expressed as a percentage of the invoice total. This practice poses three problems:
It is precisely this mechanism that France prohibits, that the AICPA prohibits in attestation engagements, and that Canadian professional bodies strictly regulate.
Conversely, a fixed fee paid for an actual matching service compensates for an identifiable service (assessing a need, introducing a prospect) at a predetermined amount, independent of the fees the accountant will subsequently bill. It creates neither the dependency nor the conflict of interest that commission bans are intended to prevent: the accountant retains the full amount of their fees and is free to set their rates with the client.
The distinction is not merely a matter of semantics: it determines compliance. The same financial transaction may be prohibited if it is classified as a commission on fees, but permissible if it constitutes fixed-price compensation for a matching service that was actually rendered. The structure of a business referral arrangement is therefore just as important as its existence.
Key takeaways. In all three countries, accepting a referred client is permitted. Compensation for the matching service is allowed with disclosure in Canada and the United States (in writing being the U.S. standard), but prohibited in France in the form of a commission on fees. In attestation engagements, any commission is prohibited everywhere. The structure of the payment, whether 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, a platform, or a partner is a common and accepted practice. Restrictions pertain to any compensation for such a referral and to maintaining independence, not to the acceptance of the client.
In Canada and the United States, yes, whenever a referral fee or commission is involved. In the United States, the AICPA Code (ET §1.520) requires disclosure; written disclosure is the professional standard, and several states expressly require it. In France, the issue does not arise in the same terms: commissions on this professional’s fees are prohibited as a matter of principle.
Article 24 of the 1945 ordinance stipulates that this professional’s fees must be exclusive of any indirect compensation from a third party. This exclusivity, designed to guarantee independence, prohibits the very mechanism of commission-based compensation, whereas the Canadian and U.S. systems permit it under certain conditions.
An assurance engagement (audit, review, or examination) requires a higher degree of independence. In both Canada and the United States, commission or referral fee arrangements are prohibited for the client in question, as they would compromise the objectivity of the accountant who vouches for the financial information.
Not necessarily. A fixed amount, established in advance and independent of the fees billed to the client, compensates for a matching service and does not constitute a commission based on those fees. The classification depends on the actual structure of the arrangement and must be verified in light of the applicable code.
In Canada, through CPA Canada and the relevant provincial accounting body. In France, on Légifrance and through the Order of accountant. In the United States, in the AICPA’s Code of Professional Conduct and with the State Board of the state where the accountant practices. Direct links are provided in the Sources section below.
Is your firm wondering how these rules fit in with a matching platform? Frequently Asked Questions from Partner Firms are addressed point by point.
Codes of professional conduct are evolving: positions taken by professional bodies, disciplinary decisions, and legislative reforms. To stay up to date, follow News for accountants.
Bankeo connects entrepreneurs with a network of over 1,500 registered accounting firms in Canada: more than 15,000 requests received since 2023, matching often done within 48 hours, and a 4.7/5 rating based on over 180 Google reviews. For a firm, this is a channel that brings in qualified clients without the need for prospecting. The process is detailed at the "How it works" page and the entire program on the Accounting Hub.
This page documents the ethical guidelines applicable to accountants’ referral of business; it does not constitute legal advice. By Arnaud Bertrand, CEO of Bankeo.
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