Can accountants receive referral fees for introducing clients?

Yes, if their professional rules allow it and the client agrees. The ICAEW Code of Ethics requires explicit written client consent to retain any referral fee or commission, whatever the amount, and ICAS requires explicit written consent for unregulated referral fees. ACCA, AAT and other bodies set their own rules. Sleeping Asset itself pays advisers no referral fee.

Do you contact our clients directly?

Only after you tell us your client has agreed to hear from us. You make the introduction, we speak to the client, and from then on we act for the client. We share progress with you only with the client's written consent, never ask your client to pay us, and stop if the client decides not to go ahead.

What kind of client is a good fit?

An established UK company with roughly 20 to 250 staff and several years of records in tools such as Microsoft 365, Google Workspace, Slack, a ticketing system or a CRM, mostly in English and about its own operations. Some buyers set higher floors: micro1 asks for 30 or more full-time staff. Clients closing a solvent company can also fit.

Will you give tax advice to our client?

No. We do not give tax, accounting or legal advice. We give you and your client the deal facts you need to advise: who the buyer is and where it belongs, what it proposes to pay, in which currency, when, and under which contract. Buyers' published prices are almost all in US dollars, and payment often follows a review period.

Can solicitors and insolvency advisers introduce clients too?

Yes, under their own rules. Solicitors must account to clients for any financial benefit from their instructions unless the client agrees otherwise, and disclose any financial interest in a referral. An insolvency practitioner in office on a case cannot keep a referral fee: the Insolvency Code of Ethics requires it to be paid into the estate and disclosed to creditors.

Accountant Referral Programme for Advisers

Key points

Good fits are established UK companies with roughly 20 to 250 staff and several years of records, mostly in English, about their own operations.
Your client pays us nothing. Buyers pay us an introduction fee when a licence completes, disclosed in writing first. See how we are paid.
We pay advisers no referral fee or share of our fee. If you receive anything for an introduction from anyone else, such as a buyer's own referral programme, your rules apply: ICAEW requires explicit written client consent to retain any referral fee or commission, whatever the amount³.
We contact a client only after you confirm they have agreed, and report back to you only with the client's written consent.

Which of your clients could have valuable records?

Established companies whose staff have spent years doing and discussing their work in cloud tools. AI developers and the data companies that supply them license these records to build and test AI agents, and each buyer publishes its own floors.

Signal	What to look for
Size	Roughly 20 to 250 staff. micro1 asks for 30 or more full-time staff⁸; Scale AI prefers 40 or more¹³; Mode's referral programme looks for 10 or more in legal, 15 or more in accounting, medical and finance, and 50 or more elsewhere⁹
History	Several years of continuous records; micro1 wants "substantial historical operational data"⁸
Systems	Microsoft 365 or Google Workspace, Slack or Teams, ticketing, CRM, project tools, code
Language	Mostly English; micro1 wants data "primarily in English"⁸
Ownership	Records about the client's own operations, not material it holds in confidence for its customers

Timing often matters more than sector: an owner planning an exit or a members' voluntary liquidation (see closing a company), a move off old systems, or a board looking for cash without new borrowing. Once a client enters insolvency, the decision passes to the office-holder; see our insolvency practitioners page. Sector limits are on our sectors page.

Weaker fits: companies under 20 staff outside legal, very young businesses, archives that are mostly HR or health records, and records mainly in other languages.

How does an introduction work?

Your client agrees first, then we take it from there. We act for the client, keep you informed only with the client's written consent, and never ask the client to pay.

You raise it with your client, using the points in the client section below.
You introduce us once the client agrees. The ICAEW Code lets accountants disclose confidential client information where the client authorises it, or where there is a legal or professional duty or right to do so³.
We hold a free, confidential 30-minute valuation call and map the records from metadata only. No data leaves the company. See what a valuation involves.
If the client goes ahead, we run each buyer's own application with them. We ask each buyer to confirm in writing that it accepts UK companies before we introduce your client. micro1 will not credit a referral if the company registered first⁸, so tell us if your client has already spoken to a buyer.
The client's own solicitor approves any licence, and the buyer pays the client under it, usually after reviewing the data. See how it works.
We tell you the outcome, if the client consents in writing.

The ICAEW Code also asks you to consider whether the party you refer a client to is fit for purpose (R331.6)³. Sleeping Asset launched in November 2026 and has no clients or completed licences yet. Our About page and fees page give you what you need to check us first.

Is there a referral programme for accountants?

Yes, but it is an introduction route, not a payment scheme. Sleeping Asset pays advisers no referral fee and no share of its fee. What you get is a clear next step for a client with years of records and, with the client's written consent, a report of the outcome. Some buyers pay referrers directly; if you accept such a payment, the rules below decide what you must do.

ICAEW. If an accountant, or an associate, receives any fee, commission, payment or benefit for referring a client, the accountant "shall obtain explicit written consent to retain the commission", regardless of the amount (R330.5B)³. Consent can come from an engagement letter clause giving "a fair indication" of the expected amount, from advance specific consent stating the amount, its basis and who pays whom, or from full written disclosure after receipt³. Acting as agent or giving professional advice creates a fiduciary relationship, the Code adds³. ICAEW's reviewers found gaps in accounting for unregulated commissions and referral fees at 51 firms; in ICAEW's words, without consent "it's the client's money"¹.

ICAS. For unregulated activity, the ICAS Code (section 330) requires explicit written consent to retain a referral fee or other benefit, received directly or indirectly; a general engagement letter clause must state the range of likely amounts⁴.

Buyers' own programmes. Buyer rewards are large and vary: micro1 publishes USD 50,000 for enterprise deals up to USD 700,000⁸, Mode pays 6% outside the US⁹ and Ventra pays referrers 50% of what it makes¹⁰. A general clause with small example amounts is unlikely to give a fair indication of sums like these, so specific written consent for each introduction looks like the cleaner route.

Regulated or unregulated? ICAEW and ICAS apply stricter rules to referrals that need a DPB (Investment Business) licence; for those, ICAEW says you cannot rely on advance general consent in the engagement letter^1,4. An introduction to a data licensing agent involves no investment or other financial product, so on our reading the unregulated rules apply. If you are unsure, ask your institute's technical helpdesk.

The law behind it. ICAEW's January 2025 article drew on the Court of Appeal's car finance ruling². The Supreme Court later allowed the lenders' appeals, but restated that a fiduciary's liability to account for profits "can be avoided if full disclosure (of all material facts) is made and the principal gives his or her fully informed consent"⁵. We hold our own fee to that standard.

Solicitors and insolvency practitioners. Solicitors must "properly account to clients for any financial benefit you receive as a result of their instructions, except where they have agreed otherwise" and tell clients of any financial interest in a referral (SRA Code, paragraphs 4.1 and 5.1)⁶. An insolvency practitioner in office on a case may not accept a referral fee unless it is paid into the estate and disclosed to creditors (R2340.7)⁷. ACCA, AAT and other bodies have their own rules.

What does your client need to know?

Five things. We go through them with your client on the first 30-minute call, and our fee and the route by which data would leave the company are set out in writing before anything is signed:

What it is: licensing a copy of operating records, with personal data removed, to AI developers and their data suppliers. The company keeps its records.
Money: the client pays us nothing; the buyer pays our fee, disclosed in writing before signing. Published prices are in US dollars, nothing is guaranteed and some companies receive no offer. See our valuation guide.
Personal data: removed to our published standard, with sensitive records left out and staff told. We prefer removal before records leave the client's systems; if a buyer removes personal data after transfer, we tell the client in writing first and the client's solicitor confirms the transfer route.
Control: the client's own solicitor approves the licence, and the client can walk away at any stage.
Your role: whether you receive anything from anyone for the introduction, how much, and the consent your rules require.

Which tax and accounting questions should you raise?

We do not give tax advice. These are the questions we expect a client's accountant to ask; we supply the deal facts to answer them.

Question to raise	Facts we provide
Currency: buyers publish prices in US dollars. How will receipts be converted and recorded?	Amount, currency and payment route
Timing: is income recognised on signing, delivery or acceptance? micro1 has 30 days to review data, then pays within 30 days of invoice¹²	Licence dates and acceptance terms
VAT: where is the licence supplied? HMRC's general rule for business-to-business services is where the customer belongs, but special rules must be checked first¹¹	The buyer's legal entity and where it belongs
Corporation tax: how is the income classified, and are legal, de-identification and subscription costs deductible?	A list of costs incurred
One-off or recurring: Scale AI says its partnerships offer the opportunity for recurring revenue¹³	The payment schedule
Closing companies: how does timing interact with a liquidation or striking off?	The proposed timetable

If you receive a referral reward from a buyer's programme, its VAT and income treatment is a question for your own firm.

Introduce a client, or ask how introductions work, on a free 30-minute call. We reply within one working day.

Accountant referral programme: help clients realise the value of their records