The Xero Partner Code of Conduct – one of my proudest achievements

During my years as the Head of Accounting at Xero I had the privilege to develop and deliver the Partner Code of Conduct. This code was one of the first of its kind worldwide when released in 2016

The link to the blog I wrote about the code is here and the link to the actual code is here.

Introducing the Xero Partner Code of Conduct

Xero recently released a Xero Partner Code of Conduct for partners to refer to in relation to Xero account access between client and advisor. This code was developed after considering multiple external resources and has intended to provide one short document to give value to advisors within the partner network and assurance to their small business clients, by enabling accurate and complete communications with clients on this issue.  

James Solomons, Head of Accounting, explains more.

The cloud has brought some great changes to the accounting industry but with change, comes new questions – such as how client-adviser relationships operate within the context of a shared data file.

Naturally, we want to know who owns the file, who owns the data, who can access the data, and who is responsible for it? To help our partners navigate this, Xero created the Xero Partner Code of Conduct.

Creating the code

The code is designed to give practical and concise guidance to accounting and bookkeeping partners on how to operate in the cloud when it comes to the issue of shared data and client projects.

It was developed in consultation with the accounting industry across Australia. This includes all the accounting and bookkeeping associations in Australia, International Association of Qualified Cloud Accountants (IAQCA), the Tax Practitioners Board (TPB) and the Xero Partner Advisory Council (XPAC).

It has been a thorough process, which has been 18 months in the works. The code officially became part of Xero’s new partner program in November 2016.

Early feedback and developments

Feedback has been positive. During Xerocon 2015, we held a panel session of industry associations and the TPB. They discussed why the code was a useful supplementary document to refer to for guidance when needed.

The TPB has since extended the theme of the code of conduct with its own release of the TPB Cloud Computing Practice Note, designed to provide further guidance to the industry.

Ultimately, this code adds value to Xero’s partners as it helps to resolve disputes that may arise. It enables access to the correct information – easily and quickly, at the right time.

The code as it was released in 2016

(it may have been updated at the time of reading)

Partner Code of Conduct

This Code of Conduct has been developed to provide a framework to assist Xero Partners in managing client relationships in a cloud accounting context, and to help prevent or deal with any disputes that they may have with their clients, partners, or employees that may involve use of the Xero platform.

This Code does not attempt to answer every question or address every issue that may arise. Xero recognises that Partners must act in the interests of their clients and may be subject to various professional standards. This Code is intended to supplement, and not detract from, those principles.

1. Scope

1.1. This Code of Conduct (Code) applies to accountants, bookkeepers or financial advisors that have accepted the Xero Partner Agreement (Partners).

1.2. In addition to helping Partners manage client relationships, this Code is intended to provide some guidance on disputes that may arise in connection with the Xero Platform, including:

a) fee disputes between Partners and their clients (Clients) which may threaten access to a Xero subscription by a business that uses Xero; or

b) any other Xero subscription ownership or access disputes, such as between Partners and their Clients, Partners and their employees or agents, or two or more persons with an interest in a Partner’s business.

2. Informing Your Clients About Xero

2.1. Partners play a key role in educating prospective Clients about their options for setting up their business on Xero. Partners should discuss and seek a written acknowledgement from their Client about who, between the Client and the Partner, will be the “Subscriber” that ultimately controls access rights to and is responsible for payment of the Xero subscription (as described in Xero’s Terms of Use).

2.2. Partners should provide materials to Clients, which might be incorporated into a letter of engagement or other document, that cover the following matters:

a) a brief explanation that cloud computing services involves the storage of files on remote servers operated by third parties, which in Xero’s case, involves the use of hosting providers in the United States of America;

b) that there is the ability for Clients to act as the Subscriber for Xero Business Edition subscriptions and to “invite” the Partner into that subscription as an “invited user”, rather than having the Partner act as Subscriber to that subscription;

c) the nature of user roles on Xero, and in particular that the Subscriber to a Xero subscription has the ability to control access rights to a Xero subscription; and

d) if it is agreed that the Partner or a party other than the Client will be the Subscriber for a Client’s business:

(i) information as to how Clients will be able to access Xero data relating to their business, including if the relationship between the Partner and the Client terminates or there is a dispute between the Partner and the Client;

(ii) what the Partner will require from the Client in order to facilitate a transition of accounting services (and/or related services) from the Partner to a new adviser; and

(iii) what dispute resolution procedures the Partner has in place and how access to the Xero subscription will be maintained in the event of a dispute (including relating to non-payment of the Partner’s fees) between the Partner and Clients.

2.3. Partners should make every effort to ensure that their employees, agents, and Clients maintain sound information technology security practices, including, for example:

a) requiring staff and Clients to use 2-step authentication within Xero;

b) implementing industry standard measures such as appropriate password management practices and ensuring appropriate anti-virus/malware software is in place;

c) seeking advice and reviews of security practices from time to time; and

d) taking advantage of guides and resources on IT security.

2.4. This clause 2 does not contain an exhaustive list of matters to be addressed with Clients. Partners should seek further advice from their professional associations in relation to requirements relating to the Client engagement process.

3. Guidance for dispute resolution

Where the Partner acts as the Subscriber to a Xero subscription in relation to a Client’s business:

3.1. Partners acknowledge and agree that any action to prevent or otherwise limit their Client’s access to a Xero subscription can cause disruption or loss to that business.

3.2. Partners acknowledge and agree that causing disruption or loss to a business, as described in clause 3.1 (i.e., by limiting or denying access to the Xero Platform), is not an acceptable strategy to recover fees from Clients or for similar debt collection purposes.

3.3. Partners must refrain from any action in relation to a Xero subscription that would hinder their Client’s ability to continue operating their business (for example, to generate invoices, run a payroll, reconcile bank transactions, file tax returns etc), even if a dispute remains unresolved between the Partner and their Client. Ongoing access to a Xero subscription whilst a dispute is being resolved can be accommodated using the process in clause 3.4.

3.4. This section does not require Partners to continue paying for Xero subscription fees indefinitely while a dispute remains unresolved between a Partner and a Client in relation to the Xero Platform. In the event that a Client requires continued access to the Xero subscription, the Partner may:

a) require reimbursement from the Client for ongoing Xero fees (being Xero’s subscription fee only) that are required in order to prevent suspension of the Xero subscription by Xero; or

b) transfer the subscription (and therefore that payment obligation to Xero, from the effective date of the transfer) to the Client (or a third party nominated by the Client) in accordance with Xero’s standard transfer process.

4. Facilitating Orderly Transitions to New Advisors

4.1. Partners must take reasonable action to co-operate with any Clients that wish to transfer their services to a new Partner or to another accountant using a platform other than Xero, including by providing or maintaining access to the Xero subscription, or transferring the Xero subscription as reasonably necessary to efficiently facilitate the transition.

4.2. This section does not require a Partner to prepare reports or otherwise undertake substantive work on the Xero Platform for the Client without charge.

5. Administration of this Code

5.1. Xero expects that its Partners will observe and comply with this Code and that, in doing so, Partners will be able to more effectively manage any disputes that may occur with their Clients in relation to the Xero Platform.

5.2. Where Xero becomes aware of a dispute between a Partner and a Client, Xero expects that in most cases the parties will be able to resolve the dispute directly between themselves (particularly if the above guidance is followed), which may involve alternative dispute or formal dispute resolution mechanisms.

5.3. Xero will endeavour to accommodate any agreed outcomes of dispute resolution processes, provided that such outcomes are reasonable and otherwise consistent with the Xero platform and Xero Terms of Use.  In the event that any parties are not able to resolve their dispute privately, Xero will comply with an order from a court that has jurisdiction to hear the matter under Xero’s Terms of Use. In some cases, Xero may be unable to take any action in the absence of a court order or mutual agreement of the parties.


Published by James Solomons

FCA, GAICD. Innovative Business Leader. Global CFO @Xref (ASX:XF1). Director at @business_Depot (formerly Aptus Accounting & Advisory @AptusAA). Former Head of Accounting @Xero Australia. Advocate, Entrepreneur & Educator #Family #Football #Fastcars!

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