Quick answer
When an accountant refers a client to a finance broker or lender, three duties matter: act in the client's interest and refer only for a real need, get the client's informed consent before sharing their financials, and tell the client in writing about any referral fee or commission. Business-purpose credit generally sits outside the consumer credit laws, but the ethics and privacy duties still apply.
Key points
- APES 110 treats referral fees and commissions as a self-interest threat; the CPA Australia summary of section 330 requires written disclosure of the fee, who pays it and how it's calculated.
- Consent under the Privacy Act has to be informed, voluntary, current and specific, so a vague line in your engagement letter is thin cover.
- Credit mainly for business purposes is generally outside the National Credit Code, but a sole trader borrowing for mixed purposes can be pulled back in.
- Share the figures the lender needs for that facility, not the whole file.
- Our referral route doesn't offer advisers fees or commissions, so there's nothing to disclose from us.
A client sits across from you, the numbers show a gap, and you say the sentence you’ve said a hundred times: “You should look at some funding.” Whether that sentence turns into a clean referral or an awkward conflict depends on a few decisions you make in the next five minutes.
This guide is for the accountant, bookkeeper or BAS agent on the other side of that conversation. It covers what you owe the client when you point them to a broker or lender, what the rules do and don’t say about business credit, and how to hand over a file without handing over too much.
What does an accountant owe a client when referring them for finance?
Three things, in this order.
- The client’s interest comes first. A referral should answer a real need the numbers support, not a convenient one. CPA Australia’s ethics commentary on referrals stresses that the introduction should fit the client’s specific situation, not just the adviser’s habit.
- Consent before data moves. The client decides what leaves your office and who receives it.
- Honesty about benefit. If anyone is paying you anything for the introduction, the client hears about it in writing.
Nothing here is exotic. It’s the same discipline you apply to any recommendation, applied to a moment where it’s easy to be casual because “it’s only an introduction”.
Do referral fees and commissions have to be disclosed?
For members bound by APES 110, yes. The Code treats a referral fee or commission as a self-interest threat to objectivity and professional competence. CPA Australia’s summary of section 330 of APES 110 says a member in public practice must inform the client in writing of any referral fee or commission, who it’s received from and how it’s calculated. APESB has been revising the Code through 2025, and paragraph numbering has moved between editions, so confirm the current compiled text with APESB or your professional body before you quote a clause in a client letter.
Practical habits that keep you clear:
- Decide before the conversation, not after, whether you’ll accept any benefit. Many practices simply decline.
- If you do receive one, put it in a short written note to the client before the introduction, naming the payer and how it’s worked out.
- Keep a copy on the client file.
On our side, advisers are not promised fees, commissions or partner benefits, so a referral to us gives you nothing to disclose. You’re making an introduction, the client fills in the same enquiry form as anyone else, and the form notes that an adviser referred them.
How much consent do you need before sharing a client’s financials?
More than most engagement letters give you. Under the Privacy Act, using or disclosing personal information for a purpose other than the one it was collected for generally needs an exception, and consent is the usual one. The OAIC’s APP 6 guidelines say valid consent means the person is adequately informed, gives it voluntarily, gives it for a current and specific purpose, and has capacity to understand it.
Run a standard engagement letter against that test. “We may share your information with third parties to provide services” isn’t informed, current or specific about a loan application. A better authority is short and dated, and says:
- who the lender or broker is (or the type, if the client is still choosing);
- what you’ll share (for example “last four BAS statements and the latest P&L”);
- for what purpose (a business loan enquiry);
- that the client can withdraw consent.
We’ve written the client-side version of this for owners: letting your accountant talk to the lender. Hand it to the client and the authority gets written in their words, not yours.
Is a business loan referral regulated like a mortgage referral?
Generally no, and this is where search results mislead. Most of what ranks online about “referral rules” comes from the home-loan world, built around the consumer credit regime and its referrer exemptions. That regime covers credit for personal, household or residential investment purposes.
ASIC’s Regulatory Guide 203 explains that credit provided mainly for business purposes, other than residential investment property, falls outside the National Credit Code, even when the borrower is an individual. The test is the dominant purpose of the borrowing.
That last point is the trap. Consider this scenario: a sole trader wants $120k, and about a third is to clear a credit card used for family expenses. Depending on how the purpose is documented and what the dominant use really is, the file can edge towards consumer territory. Fixing it is simple: keep personal and business purposes separate in the application, and tidy the finances first (see separating business and personal spending).
So the absence of consumer-credit referral rules doesn’t mean an open field. Your professional obligations, the Privacy Act and plain good practice all still apply. If you’re unsure how the credit rules treat a particular client, that’s a question for a lawyer, not for the broker you’re referring to.
Broker, lender or marketplace: which should you refer to?
The right answer depends on the client, not on who is easiest. A quick sort:
| Client situation | Referral that usually fits |
|---|---|
| Strong trading history, wants to compare several lenders | A broker who explains how they’re paid |
| Needs one workable option, has documents ready | A single matched introduction |
| Owns property and wants equity | A secured-lending specialist |
| Has an ATO debt or past defaults | Someone who will read the evidence case by case |
For a fuller look at the roles, see who does what between accountant, broker and lender. Whichever route, ask the same two questions before you introduce anyone: how are they paid, and what happens to the client’s details after the first call?
What should you send, and what should you hold back?
Send what the facility needs, nothing more. Over-sharing is the most common referral mistake, and it quietly breaches the “specific purpose” idea above.
- Cash flow or line-of-credit lending: recent BAS, bank statements, and a current P&L. Our page on BAS statements and cash flow lending explains how they’re read.
- Secured lending: entity details, a statement of assets and liabilities, and property information.
- Hold back: tax returns for unrelated years, personal matters, notes on other clients’ entities, and anything the client hasn’t seen.
If something awkward sits in the file (a late lodgement, an ATO payment plan, a loss year), explain it to the lender rather than hoping it isn’t noticed. A short note from you, along the lines of writing an accountant letter, usually helps more than silence.
A worked example of a clean referral
Say a client runs a landscaping business, and the Q1 BAS you’re lodging shows strong turnover but tight cash after buying a second truck. You think a line of credit would smooth the winter months.
- You tell the client what you’ve seen and why a facility might help, and you ask whether they’d like an introduction.
- You confirm you receive no benefit from the referral, and note that in the file.
- The client signs a one-page authority covering their last four BAS, bank statements and the latest P&L, for a business loan enquiry.
- You or the client complete the enquiry, flagging that an adviser referred them.
- A specialist calls the client, and, with the client’s say-so, calls you for anything the numbers don’t explain.
Total effort on your side is short, the client stays in charge, and the paper trail shows you did it properly. How to refer a client walks through the mechanics in more detail.
If a client is ready now, you can check their options through our enquiry form and note that you referred them.
Where referrals go wrong
- Referring first, asking later. The client finds out their data is with a stranger.
- The undisclosed benefit. Even a modest one, if it surfaces later, damages the relationship far more than the amount involved.
- Sending the whole file. Lenders don’t need it, and the client didn’t agree to it.
- Letting the broker become the client’s only voice. You know the numbers; stay available to explain them. See adviser–lender collaboration.
Want a hand with a client who needs funding?
If you have a client in front of you now, you can check where they stand without committing them to anything. The enquiry takes about 60 seconds, and there’s no credit check when you enquire, so their credit file stays exactly as it is. We don’t send your client’s details to a pile of lenders; a real person looks at the individual situation, links it to a lender that suits, and calls the client (and you, if they’d like). The one thing we ask is that the form is filled in accurately, so the first match is the right one.
Frequently asked questions
Can an accountant refer a client to a business loan broker?
Yes. Referring a client to a broker or lender is common practice. The professional questions are whether the referral suits the client's need, whether the client has agreed to you sharing their information, and whether you receive any benefit that must be disclosed to them in writing.
Do I have to disclose a referral fee to my client?
If you're a member bound by APES 110, yes. CPA Australia's summary of section 330 says a member in public practice must tell the client in writing about any referral fee or commission, who it comes from and how it's calculated. Check the current compiled Code, or your professional body, for the exact wording that applies to you.
Do I need the client's consent to pass their financials to a lender?
Get it, and get it in writing for the specific purpose. The OAIC's APP 6 guidelines say consent must be informed, voluntary, current and specific. A blanket clause in an engagement letter signed years ago may not meet that, so a short, dated authority for this referral is safer.
Is business finance regulated under the NCCP Act?
Generally not. ASIC's Regulatory Guide 203 says the National Credit Code covers credit mainly for personal, household, domestic or residential investment purposes, and that credit mainly for business purposes is outside it. The test is the dominant purpose of the borrowing, so mixed-purpose loans to individuals need care.
Do you pay accountants a fee for referring clients?
No. Advisers are not promised fees, commissions or partner benefits for introducing a client. A referral uses the same short enquiry form, with a note that an adviser referred the client, and the client stays the decision-maker.
What should I send when I refer a client?
Only what's relevant to the facility being discussed, and only with the client's agreement. For cash flow lending that is usually recent BAS and bank statements; for secured lending it is entity details and property information. Everything else can wait until a lender asks for it.
Does the client's credit file get checked when I refer them?
Not when they enquire with us. There's no credit check at the enquiry stage. A credit check only comes up if the client chooses to proceed with a specific option.