Quick answer: Yes, an accountant may be able to receive a referral fee or commission for introducing a client to a finance broker, but the arrangement is not 'payment with no rules'. APES 110 requires accountants to address threats created by referral fees and commissions, while consumer-credit referrals can also trigger ASIC licensing or referral-exemption requirements.
This question has two separate parts: can the broker pay? and can the accounting practice accept it in the circumstances?
APES 110 expressly contemplates referral fees and commissions
APES 110 recognises that a member in public practice may receive a referral fee relating to a client or commission from a third party. It also says that this creates a self-interest threat to objectivity and professional competence and due care.
The practice therefore needs to assess and address the threat and comply with the applicable disclosure and independence requirements.
Consumer-credit referrals have another layer
ASIC says a person who engages in consumer-credit activity generally needs a credit licence, authorisation or exemption.
A simple upstream referral may fit the referral exemption when its conditions are met. RG 203 lists requirements including a written referral agreement, client consent, passing contact details within five business days, and disclosure of any commission or benefit.
That is different from giving the client a recommendation about a particular loan.
Does the same answer apply to every accounting client?
No.
An ordinary business-services client, an audit/review client and a client receiving another assurance service can raise different independence considerations. APES 110 contains specific assurance-independence requirements.
The practical answer is to establish the referral model at practice level rather than deciding from scratch each time a finance opportunity appears.
What can GPS Finance document?
A partner arrangement can set out:
- permitted introduction process;
- information that can be passed to GPS;
- communication boundaries;
- partner remuneration;
- timing of payment;
- handling of client consent and required disclosure;
- circumstances where remuneration is not payable.
That keeps the finance relationship commercial without making the arrangement casual.
Related referral guides
- Finance referral income for accountants
- Do I need a credit licence to refer finance?
- APES 110 and referral-fee disclosure
- How finance referral partnerships work
Sources and verification
- APESB — APES 110 Code of Ethics
- ASIC — FAQs: Does the credit legislation apply?
- ASIC — Regulatory Guide 203: Do I need a credit licence?
General information only. Referral, licensing, professional-conduct, tax and disclosure obligations depend on the activity, profession, client and arrangement. This is not legal, tax or accounting advice. Check the requirements that apply to your practice before relying on a referral exemption or accepting remuneration.
Need help matching this to a business-finance option?
GPS Finance can review the funding purpose, conduct, documents and lender fit before you make a formal enquiry.
