Are You Earning Fees from Property Deals? What Accountants Need to Know About the PPRA
This article will count 0.25 units (15 minutes) of unverifiable CPD. Remember to log these units under your membership profile.
If you are facilitating property transactions and earning a fee for it, the law may already consider you an estate agent — whether you intended that or not.
This is not a grey area. The Property Practitioners Act, 2019 is clear, and accountants who step into this space without the correct registration are exposing themselves to serious legal and financial risk.
The Law Looks at What You Do, Not What You Call It
Many accountants assist clients with property transactions as part of broader advisory work. In some cases, they negotiate sale terms, help structure deals, or broker a purchase price, and charge a fee that is linked, directly or indirectly, to the value of the transaction.
The problem? Calling that fee a "professional fee" instead of a "commission" does not change its legal character. The Property Practitioners Act applies the principle of substance over form, it looks at the nature of the activity, not the label attached to it.
If you are doing any of the following, you are likely acting as a property practitioner in the eyes of the law:
Negotiating the sale of a property on behalf of a client
Helping to structure a property deal
Brokering the selling price between parties
Earning a fee that is calculated as a percentage of, or linked to, the purchase price.
What the Law Requires
Under the Property Practitioners Act, anyone who performs these functions must:
Be registered with the Property Practitioners Regulatory Authority (PPRA), and
Hold a valid Fidelity Fund Certificate (FFC)
These are not optional. There are no exemptions that apply simply because you are a qualified accountant or because the activity forms part of a broader service offering.
The Consequences of Non-Compliance
Operating as a property practitioner without the required registration carries real consequences:
You cannot legally claim or enforce your fee, even if the client agreed to pay it
You may face penalties under the Act
You will be non-compliant, which poses a risk to your professional standing and your practice.
This is particularly important for accountants in public practice who value their professional reputation and their relationship with regulatory bodies, including CIBA.
What You Should Do Now
If you have been earning facilitation fees from property transactions, act promptly:
Stop charging or receiving facilitation fees until your compliance status is confirmed
Apply to register with the PPRA if you intend to continue offering these services - download the brochure on How to be a Property Practitioner.
Consult a lawyer to assess and address any risk arising from past transactions
If you are unsure whether your activities fall within the definition of a property practitioner, err on the side of caution and seek legal advice before continuing.
The Bottom Line
Accountants are trusted advisers, and that trust depends on operating within the boundaries of the law at all times. The PPRA registration requirement is not a technicality to be managed — it is a legal obligation with enforceable consequences.
If you are earning money from facilitating property sales, you must be registered. It is that straightforward.
