Picture the email a partner manager at a UK app company dreads. One of their best referring firms, a 30-person practice in the Midlands, is pausing referrals. Nothing is wrong with the product. The firm’s compliance partner has just been through a practice assurance visit, and the reviewer asked to see written client consent for every commission the firm keeps. The firm had none for the app’s 15% referral fee. It now has to write to dozens of clients, tell them what it earned, and ask permission to keep it.
The firm doesn’t blame the professional body. It blames the vendor whose payment created the paperwork.
Most vendors design their referral payments as if accountants were affiliates. They aren’t. Accountants are regulated professionals with a code of ethics that treats your payment as a threat to their objectivity. That code doesn’t stop them taking your money, but it decides how they can take it. A partner program that ignores it is asking its best firms to carry a compliance risk on your behalf.
TL;DR
- Referral fees are allowed, not invisible. In the UK a firm needs the client's written consent to keep your fee. In the US it can't take a commission at all from a client it audits or reviews.
- The paperwork lands on the firm. ICAEW found gaps in how 69 firms accounted for commissions and referral fees in a single year of monitoring visits.
- Design for disclosure. A per-client statement of what each firm earned is worth more to a partner than another five points of commission.
- Offer a non-cash route. Let the firm pass the value to its client as a discount, and let it switch commission off client by client.
- Don't advise on their ethics. Build the options, then let each firm check with its own body.
What the codes actually say
Every major accounting body works from the same root: the international code of ethics issued by IESBA, which treats a commission or referral fee as a self-interest threat to the accountant’s objectivity. Each body then adds its own rules on top. The details below are as of October 2026, from each body’s own published guidance. Check them before you put them in a contract.
The UK: consent before they keep it
ACCA’s factsheet on commissions and referral fees, issued in December 2024, is the clearest statement of the rule. Members must “account to the client” for every commission and referral fee. That means:
- telling the client in the engagement letter that the firm may receive them
- getting the client’s written consent to retain them, without which the firm cannot keep the money
- keeping records of every amount received for at least six years
- as best practice, sending the client a statement of the actual amounts, at least once a year
The factsheet names app providers specifically. It gives their typical referral fee as up to 20% of the monthly fee charged to the client, usually £10 to £50 a month. Your payment is not an edge case. The rules were written with you in mind.
ICAS applies the same principle under section 330 of its code: explicit written consent, plus telling clients in writing what they earned and that the client can ask for it to be handed over. ICAEW’s code requires the same consent, and its regulators found gaps at 69 firms during 2023’s practice assurance visits — firms that hadn’t told clients how much they received, or hadn’t obtained consent to keep it (ICAEW, February 2024).
The US: no commissions from attest clients
The AICPA’s Commissions and Referral Fees Rule (ET 1.520) works differently. A CPA firm cannot accept a commission for recommending a product to a client for which it performs certain attest services, such as an audit or a review. For other clients it can, but it must disclose the commission to the client in writing. Many state boards of accountancy carry their own version of the rule, so the details vary by state.
The practical consequence for a vendor is easy to miss. The same firm may be allowed to take your commission on one client and forbidden from taking it on the next, depending on what other work it does for each.
Australia: in the terms of engagement
In Australia, APES 110 deals with fees and other remuneration in section 330, and APES 305, revised with effect from 1 January 2020, expects a firm’s terms of engagement to set out the basis and calculation of its fees, explicitly including referral fees and commissions. Firms that are also licensed for financial advice face stricter rules again. The direction is the same as the UK’s: the client is told, in writing, up front.
Why this is your problem, not just theirs
A vendor can reasonably say that a firm’s ethical obligations belong to the firm. That’s true, and it’s also the fastest way to lose your best partners.
Look at it from inside the practice. A firm that refers a few clients a year to you takes on a duty to update its engagement letters, get signed consent, track every payment per client, and produce a statement once a year. If your payment is £15 a month per client, the admin can easily cost the firm more than the fee earns. The partner who championed you then has to explain all that to the compliance partner. As we covered in who really signs off software inside an accounting firm, that’s a gatekeeper you didn’t plan for.
So the firms that are most careful about their obligations, usually the larger, better-run firms you most want as partners, are the ones most likely to quietly decline the cash and refer you less. That’s the opposite of what your program was designed to do.
There’s a second cost. A firm that is seen to recommend software because it’s paid to has a reputation problem with its own clients. The disclosure rules exist because clients care. If your payment is the reason a firm recommends you, rather than a thank-you for a recommendation it would have made anyway, you’ve made it harder for the firm to recommend you with a straight face.
Our verdict: design a payment a firm can accept in the open
Don’t drop referral fees. Recurring payment keeps a firm invested in a client staying on your product, which is why we argued for it in how to build a partner program. But build the payment so the firm can take it openly, or turn it down without losing anything.
1. Ship the disclosure, not just the payment
The single most useful thing you can give a partner firm is a per-client statement: which clients you paid on, how much, and when, in a format the firm can attach to its annual client statement or hand to its compliance partner. Put it in the partner dashboard. Make it exportable.
This costs you very little. Your billing system already knows the numbers. For the firm, it turns a compliance chore into a download. No competitor’s partner manager will mention it in a pitch, which is exactly why it wins.
2. Let the firm pass the value to the client
Offer every partner the choice between a cash fee and a client discount of equivalent value. A firm that chooses the discount has received nothing to retain. ACCA’s guidance, for one, says there is no requirement to disclose fees a firm doesn’t keep, so the paperwork usually shrinks to almost nothing. It also has a better story for the client: we got you a better price instead of we get paid when you sign up.
Some firms will always want the cash, and that’s fine. The point is that the firm that doesn’t want the paperwork still has a reason to recommend you.
3. Switch commission off client by client
For US partners especially, a firm needs to be able to say not this client without leaving your program. Build a per-client flag that stops payment on any client the firm marks, with no questions asked. A program that pays a commission the firm isn’t allowed to accept forces the firm to send the money back, explain why, and wonder what else you’ve got wrong.
4. Make the payment the thank-you, not the reason
The firms that send the most clients to vendors do it because the product makes their service better. That’s the argument in partner enablement, and it holds here too. Lead your partner pitch with what the firm can do for clients with your product. Mention the referral fee last. A firm that would recommend you without the fee will happily take it. A firm that would only recommend you for the fee is a firm whose clients will eventually ask why.
5. Don’t tell a firm what its own code allows
You’ll be asked. Is a resale margin a commission? Do we need consent for the discount? Don’t answer. When a firm bills your product to its client as part of its own fee, it may be selling a service rather than receiving a payment for an introduction, and its body may treat that differently. But that’s for the firm and its body to decide, not you. Give firms clear facts about what you pay and how, and point them to their own body. A vendor giving ethics advice to accountants is overstepping, and the relationship goes worse when that advice turns out to be wrong.
What this looks like in the partner pitch
The version of this that works sounds like this:
We pay partners a recurring fee on every client they bring. You can take it as cash or give it to your client as a discount. Either way, you get a statement of every payment per client for your records, and you can switch it off for any client at any time.
Three sentences, and the compliance partner has nothing left to object to. Compare that with a one-line 15% recurring commission on a partner page, and think about which one gets past the firm’s gatekeeper.
The bodies notice who makes this easy
There’s a longer game here too. The professional bodies are not hostile to software vendors. ACCA’s factsheet exists because its members are being paid by app providers and need to get it right. A vendor that makes compliance easy for members is a vendor a body can talk about without discomfort. As we wrote in what professional bodies actually want from a software vendor, substance and longevity open those doors. A partner program that respects their members’ obligations is both.
Partner economics, payment design and enablement sit inside our channel and partnerships work. Related reading: who pays in the channel, how to raise prices on accounting firms without losing them, and what firms need before they’ll recommend you.
