How CPAs Can Earn Referral Fees on Workers’ Comp and PEO Referrals in Florida

If you work with contractors, construction companies, or any Florida employer with a payroll, you already know the pattern. A client calls about their year-end tax return and the conversation turns to a workers’ comp audit bill they didn’t expect. Another client asks whether a PEO arrangement would save them money on benefits. A third wants to know why their general liability premium jumped 40% after an audit.

These are not insurance questions in the traditional sense — they are business and compliance questions that land in your office because you are the trusted advisor in the room. The problem is that most CPAs, bookkeepers, and tax professionals don’t have a structured way to monetize those referrals or to ensure their clients get expert help quickly.

Florida law provides a clear path to do both. Understanding the legal framework — and the specific products where no insurance license is required at all — is the starting point.

Florida Statute §626.112(8) permits a licensed insurance agency to pay a flat referral fee to an unlicensed person for directing prospective buyers to the agency, subject to one critical condition: the fee cannot be contingent on whether the referred person actually purchases a policy. A flat fee per qualified referral — regardless of outcome — is permissible. A commission tied to a sale is not.

What this means in practice is straightforward. A CPA who tells a client “you should talk to Bright Coast Insurance about your workers’ comp situation” and receives a flat fee for that introduction is operating within the law. What the CPA cannot do without a 2-20 Property & Casualty license is describe specific coverage terms, compare policy options, advise on which carrier to choose, or negotiate on the client’s behalf.

The distinction matters. Referring is legal. Advising on insurance is not — unless you are licensed. Most CPAs are already operating within this line naturally; they refer clients to specialists all the time. The referral fee program simply compensates them for doing what they already do.

It is worth noting that the AICPA’s ethics rules (Section ET 1.520) address referral fees and commissions for CPAs. The rules generally permit referral fees with client disclosure. Florida CPAs should review their state CPA society’s guidance and consult their own ethics advisor before participating in any fee-sharing arrangement.

The most important thing for CPAs to understand is that several of the products most relevant to their contractor clients are not insurance products at all — which means there is no insurance license requirement for referring them, and no restriction on how the referral fee is structured.

Professional Employer Organization (PEO) services are governed by Florida Chapter 468, not the Insurance Code. A PEO is a co-employment arrangement in which the PEO becomes the employer of record for payroll, HR compliance, and benefits administration. Workers’ compensation coverage is provided under the PEO’s master policy — eliminating the individual employer’s exposure to annual audits. Referring a client to a PEO is not an insurance referral; it is a business services referral.

Payroll processing services are purely administrative. Referring a client to a payroll provider requires no license of any kind.

Workers’ comp audit defense is a consulting and representation service. When a carrier audits a policyholder and produces an unexpected bill, audit defense involves reviewing the audit methodology, disputing incorrect classifications, and negotiating the final premium. This is not an insurance product — it is a professional service, similar in nature to tax dispute representation. CPAs are often uniquely positioned to identify clients who have been overcharged in an audit, because the audit bill shows up in the financials they are already reviewing.

General liability audit defense works the same way. GL policies for contractors are typically audited annually based on payroll or revenue, and overcharges are common — particularly for roofing contractors whose subcontractor documentation is incomplete.

Not all referrals are created equal. For CPAs who work with Florida contractors — roofers, general contractors, electricians, plumbers, HVAC companies, framing crews — the referral opportunity is particularly concentrated because these clients face a specific and recurring set of insurance and compliance challenges.

Workers’ compensation is mandatory for most Florida contractors with employees, and the annual audit cycle creates predictable friction. A roofing company with $2 million in payroll may face a workers’ comp audit bill of $30,000 to $80,000 — and in many cases, a significant portion of that bill is disputable if the right documentation is in place. CPAs who review their clients’ financials at year-end are often the first to see an unexpected audit charge and the first to hear “is there anything we can do about this?”

PEO arrangements are increasingly popular among Florida contractors as a way to eliminate the audit cycle entirely. Under a PEO, workers’ comp is billed as a percentage of payroll each pay period — there is no annual audit because there is no individual policy to audit. For a contractor who has been hit with large audit bills in prior years, the PEO model can represent a significant and immediate financial benefit.

The mechanics of a referral are intentionally simple. When a client situation comes up that involves workers’ comp, general liability, PEO, payroll, or audit defense, the CPA makes an introduction — either by providing the client with the agency’s contact information or by sending a brief email connecting the two parties. The CPA does not need to explain coverage terms, compare options, or stay involved in the transaction.

Bright Coast Insurance handles the follow-up, the needs assessment, and the service delivery. The CPA receives a flat referral fee for the introduction, documented in a partner agreement that specifies the fee structure and payment terms. For PEO, payroll, and audit defense referrals, the fee structure is based on the service agreement and is not subject to the insurance referral fee restrictions described above.

The partner registration process is straightforward: complete a brief online registration through the Bright Coast agent portal, review and sign the partner agreement, and begin making introductions. There is no production minimum, no exclusivity requirement, and no ongoing obligation.

This post provides general information about Florida law and the structure of Bright Coast Insurance’s referral partner program. It does not constitute legal or ethics advice. CPAs, bookkeepers, attorneys, and other licensed professionals are responsible for ensuring that their participation in any referral arrangement complies with their own professional ethics rules and applicable law.

For CPAs, the relevant guidance is AICPA Section ET 1.520 (Referral Fees and Commissions) and the Florida Institute of CPAs’ ethics resources. The key requirement under AICPA rules is disclosure to the client — the client should know that you may receive a referral fee for the introduction.

If you work with Florida contractors, employers, or small businesses and you want a structured way to add value for your clients while generating ancillary revenue, the Bright Coast Insurance referral partner program is designed for professionals in your position. The program covers workers’ comp, general liability, PEO, payroll, and audit defense — the full range of products that your contractor clients need most.

To learn more about the program, the fee structure, and the partner agreement, visit our Referral Partner page or call us at (239) 323-0785. Spanish-speaking agents are available.