What a CPA Firm Needs to Know Before Paying for Referrals

The AICPA Code of Professional Conduct's commissions and referral fee rule generally requires a CPA who receives a commission or referral fee to disclose that arrangement in writing to the client. State boards can layer on additional requirements, and the rule interacts differently with attest versus non-attest clients, so the exact obligation in your situation depends on jurisdiction and engagement type. Settle what needs to be disclosed, and to whom, before building a referral program around it, not after a client asks why their tax preparer recommended a specific bookkeeping vendor.

Once a firm decides it will accept referral fees from software vendors, bookkeeping platforms, or other advisory services, PartnerStack gives partners and staff a portal to register the referral, tracks the commission tier against the vendor's billing, and issues payouts with the tax paperwork handled. What it does not do is generate the client disclosure. That has to happen separately, ideally as a standard form attached to any engagement where a referral fee is in play.

A firm that partners with a wealth management group, a business banking team, or a software vendor for referrals in the other direction can use Crossbeam to compare client lists and surface overlaps, so a partner knows a prospective client already works with an ally before making an introduction. No commission changes hands in this direction typically, and no disclosure obligation is triggered by simply knowing an overlap exists, though it would be triggered the moment a referral fee gets attached to it.

Start by drafting the disclosure language and getting it reviewed, since that governs every referral relationship the firm will ever have, whichever software tracks it. Only after that's settled does it make sense to decide whether PartnerStack's payout tracking is worth the setup for the volume of referrals the firm actually generates. Many smaller firms find that volume doesn't justify the platform yet, and a disclosure template plus a tracked spreadsheet covers the need for another year or two.

Follow this sequence before you buy anything:

1. Draft the client disclosure language for referral fees and have it reviewed, since it governs every referral relationship the firm will ever have.
2. Confirm the AICPA and state board requirements that apply, including limits on commissions for clients receiving certain attest services.
3. Decide whether PartnerStack's payout tracking is worth the setup for the volume of referrals the firm actually generates.
4. Keep a record for each referral of the client, the vendor, the fee, and whether and when disclosure went out.

The common mistake isn't choosing the wrong software, it's treating referral fee disclosure as optional paperwork rather than a professional standards requirement. A referral relationship that pays well but was never disclosed to the client creates real risk for the firm, independent of whether the tracking behind it was a spreadsheet or a platform. Get the disclosure practice right first, and the software choice becomes a much smaller decision.

The most common referral fee arrangement at a smaller firm involves a bookkeeping or accounting software vendor paying for client migrations. Before agreeing to any such arrangement, confirm whether the specific vendor relationship is structured as a referral fee, an affiliate commission, or a reseller markup, since the disclosure obligation and the way PartnerStack would track it differ across those structures. A vendor's own sales team can usually explain how their program is structured, but the firm's compliance resource should confirm what that means for the firm's disclosure obligations before the first client gets referred.

Whatever system tracks referral fees, whether a spreadsheet or PartnerStack, it should produce a clean record on request: which client, which vendor, what fee, whether disclosure went out and when. That record matters beyond day-to-day operations, since a peer review or state board inquiry can ask for exactly this history. Firms that build the habit of logging disclosure alongside the referral itself, rather than treating them as two separate tasks handled by different people, tend to have a much easier time producing that record when it's actually requested. A single shared tracker that a designated partner reviews monthly is usually enough to keep this from slipping between busy seasons.