TL;DR
- A contract and invoice do not, by themselves, justify paying a local introducer’s commission.
- Before releasing funds, establish who will receive the money, what was delivered, how the fee was calculated, whom the payment may influence, and who approved it.
- A mismatched payee, personal bank account, undisclosed relationship, promised outcome, or unidentified beneficial recipient should trigger a pause and escalation.
- The decision should rest on mutually supporting evidence, not the claim that “this is how business is done locally.”
Chinese companies pursuing customers, projects, or licences in the UAE may be asked to pay a local “introducer” a commission based on the value of a successful deal. The most common mistake is to treat an executed agreement and an invoice as sufficient grounds for payment, leaving finance to process the transfer as a routine administrative step.
This article addresses the practical question that comes before payment, rather than the overly broad question of whether introducer fees are legal. It gives your business a five-question evidence chain for deciding whether to proceed, request more documents, pause and escalate, or refuse the payment.
Why Are a Contract and Invoice Not Enough to Support Payment?
A legitimate commercial introduction may be compensated, and a success fee is not inherently improper. The problem is that a contract and invoice mainly document a request for payment. On their own, they do not prove that the service occurred, that the amount is commercially reasonable, that the named payee performed the work, or that the payment is free from improper influence.
Your business should instead test whether five groups of information support one another: the recipient’s identity, the services delivered, the commission calculation, the payment’s true purpose, and the internal approval. If any link cannot be explained, finance should not release funds merely because the deal is progressing.
Pause the payment if any of these warning signs appears:
- The contracting party, invoicing party, and bank account holder do not match.
- The introducer requests cash or payment to a personal or unrelated third-party account.
- The introducer will not disclose relationships with the customer, public officials, your employees, procurement personnel, or decision-makers.
- The service is described only as “relationship coordination” or “project support,” with no performance record.
- The introducer claims to be able to secure an approval, influence a decision, or guarantee a specified result.
- The agreement is executed late or backdated, or the introducer asks to split invoices or rename the fee.
⚠️ These circumstances do not establish that misconduct has occurred. They do establish that the available evidence is insufficient to support payment. “Pay now, document later” transfers commercial pressure into compliance exposure for your business.
Question 1: Who Will Receive the Commission?
Identity checks should begin with the legal name, registration details, beneficial ownership, authorised signatory, and bank account name. If the introducer is an individual, verify the person’s identity and eligibility to provide the relevant service. If it is a company, confirm that contracting, invoicing, and receiving payment are handled by the same legal entity.
Obtain a written relationship declaration covering family, employment, investment, and other interests involving the customer, public officials, your employees, procurement personnel, and ultimate decision-makers. If the contracting party, receiving account, or beneficial recipient later changes, repeat the review rather than relying on the original approval.
Escalate immediately for independent legal review if the introducer is connected to a public-sector official, a person entrusted with a public service, or markets an ability to influence another person’s conduct. UAE federal criminal legislation contains rules addressing bribery, offering bribes, and profiting from influence. Calling a payment an “introducer fee” or “consultancy fee” does not change the need to examine its true purpose. (Source: UAE Government Legislation Platform, Federal Penal Code, September 2026; subject to the latest official publication and advice from appropriately qualified counsel in the relevant jurisdiction.)
💡 Our recommendation is to establish who ultimately benefits from the funds before focusing on supplementary paperwork. An invoice can be corrected; an unexplained beneficial recipient removes the basis for proceeding.
Question 2: What Services Did the Introducer Actually Provide?
“Introducing a customer” is not directly verifiable. Break the description into observable actions and outcomes:
- Where did the lead originate, and when was the first contact?
- Which meetings were arranged, and who attended?
- Did the introducer provide translation, tender coordination, or negotiation support?
- What specific result triggered the commission, and who confirmed its completion?
Emails, calendar invitations, meeting minutes, customer confirmations, milestone outputs, and delivery records can collectively demonstrate performance. The introducer’s own verbal account is not enough.
Your business must also separate legitimate services from promised outcomes. An introducer may arrange meetings, relay public information, or support communication. If the basis for payment becomes “the licence will definitely be approved” or “a specified person will make the decision,” the nature of the payment has changed. Stop the routine approval process and refer the transaction to compliance and legal advisers.
Question 3: Why Is the Commission This Amount?
A fixed fee should state the service period, scope of work, and payment milestones. A success fee should identify the calculation base, percentage, triggering event, cap, refund arrangement, and exceptions. Someone independent of the introducer’s business sponsor should confirm that the trigger was met.
There is no universal “safe commission percentage.” Sector norms, effort, transaction value, and commercial circumstances vary, so a single benchmark cannot replace a commercial reasonableness review. If the introducer raises the fee at the last minute, requests an amount disproportionate to the work, or adds a charge just before approval, the business team should provide a written explanation supported by the calculation, budget basis, and completed work.
Legal, tax, and accounting reviews answer different questions. A fee that can be recorded as an expense has not necessarily been earned. A defensible tax treatment does not establish that the payment purpose meets anti-bribery requirements. Tax and accounting treatment should be confirmed against current requirements from the relevant authorities and appropriate professional advice.
Question 4: Whom Is the Payment Intended to Influence?
Trace the payment to its real purpose. Is it connected to winning a project, licence, approval, exemption, or other improper advantage? Has the introducer suggested that part of the commission will be transferred to someone capable of affecting the result?
Descriptions such as “relationship fee” or “facilitation fee,” a promise of a specified outcome, or refusal to disclose the ultimate recipient should activate a stop mechanism. Confidentiality or claimed local custom is not an adequate explanation. Where a government customer, approval contact, or public function is involved, increase the level of scrutiny: verify identities and relationships, prohibit unapproved subcontracting or onward payment, and ask counsel qualified in the relevant jurisdiction to review the transaction.
Your business does not need to prove that an offence has already occurred before pausing payment. If the purpose or destination of the funds cannot be reasonably explained, the evidence is not sufficient to release them.
Question 5: Could Your Business Reconstruct the Entire Transaction Six Months Later?
A defensible introducer fee cannot depend on the case handler’s memory. If finance, compliance, or audit personnel change, the file should still show who made the introduction, when it happened, what work was done, what outcome resulted, and who confirmed and approved it.
Responsibilities should be separated. The business sponsor identifies the need and confirms delivery. Compliance or legal advisers examine identity, relationships, and payment purpose. Finance verifies the invoice, tax treatment, commission calculation, and account consistency. The authorised approver decides on the basis of the complete file. One employee should not select the introducer, validate the outcome, set the commission, and demand payment.
At minimum, the agreement should cover scope, fee triggers, conflict disclosures, prohibited payments, subcontracting restrictions, evidence rights, and termination and recovery rights for false information. The performance file should preserve due diligence, communications, confirmation of outcomes, calculations, and approvals in chronological order.
How Should the Five-Question Evidence Chain Determine Whether to Pay, Supplement, or Stop?
Do not limit payment approval to asking whether all expected documents are present. Test whether the five groups of evidence correspond with one another.
| Review question | Primary owners | Minimum evidence | Pause trigger | Escalation route |
|---|---|---|---|---|
| Who is the recipient? | Business, compliance | Identity or registration records, beneficial ownership, relationship declaration, account evidence | Entity mismatch, hidden relationship, unidentified beneficial recipient | Compliance, legal |
| What was delivered? | Business | Service description, emails, meeting records, outcome confirmation | No performance trail, vague service description | Business lead, compliance |
| Why this amount? | Business, finance | Commission calculation, budget, commercial rationale | Last-minute increase, unclear base or percentage | Finance lead, authorised approver |
| Whom may it influence? | Compliance, legal | Payment-purpose statement, public-sector relationship checks, anti-bribery terms | Promised outcome, suspected onward payment, improper influence | Independent counsel, management |
| Who approved payment? | Finance, authorised approver | Risk review, tax verification, approval record, payment evidence | No separation of duties, incomplete approval file | Management |
The review should lead to one of four clear outcomes:
- Proceed: All five questions are supported by consistent evidence; pay through the authorised process.
- Obtain documents and reassess: The service may be genuine, but identity, outcome, amount, or account evidence is incomplete.
- Pause and escalate: The transaction involves a public function, concealed relationship, unusual payment route, or unidentified beneficial recipient.
- Refuse payment or terminate the relationship: Legal and compliance review confirms an improper purpose or false information, or the introducer refuses remediation.
What Mistakes Do Chinese Companies Commonly Make When Approving Introducer Fees?
| Common mistake | More defensible approach |
|---|---|
| The business team verbally promises a percentage and completes the paperwork only when finance must pay | Complete onboarding, budget, and authority approval before committing to a commission |
| A contract and invoice are treated as automatic approval | Check identity, relationships, performance, amount, purpose, and approval together |
| Finance checks the account number but not the account name | Compare the contracting party, invoicing party, account holder, and beneficial recipient |
| The introducer changes the receiving company but the original approval is reused | Repeat the review whenever the entity, account, or beneficial recipient changes |
| “Project success” substitutes for confirmation of deliverables | Define the trigger and require independent confirmation of the specific outcome |
The later the review begins, the more likely the team is to be constrained by “the deal has already closed” and “the introducer is chasing payment.” A stronger sequence is to register identity and relationships at first contact, define the service and fee before contracting, preserve evidence during performance, and conduct only a final reconciliation at payment.
Action Checklist Before Payment
- Verify the introducer’s identity, relationships, and beneficial ownership before committing to a commission.
- Break “customer introduction” into verifiable actions, outcomes, and payment triggers.
- Record the calculation base, percentage, cap, and commercial rationale.
- Pause if the request involves a personal account, third-party collection, public-sector relationship, or promised result.
- Separate business confirmation, compliance review, finance verification, and final approval.
- Retain the agreement, performance evidence, and payment records needed to reconstruct the full transaction.
If you are assessing an introducer commission in the UAE, the next step is not simply to obtain another invoice. First establish whether identity, service, amount, purpose, and approval form a coherent evidence chain. We can help your business identify the critical decision points in third-party due diligence and payment approval, and connect you with appropriate specialists where transaction-specific legal or tax advice is required.
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Last updated: September 2026. This content is for informational purposes only and does not constitute legal or tax advice. For professional consultation, please contact the MIRISE team.