Matthew L. Berman
Class actions · Employment · Civil rights
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Knowledge Base

New York Sales Commissions Law

If you sell for a living in New York, the commissions you earn are protected by law. How they are protected depends on one question: are you an employee who gets a W-2, or an independent contractor who gets a 1099? The rules, the deadlines and the remedies are different. Start by finding your track.

Which track are you on?

If you get a W-2
Taxes come out of your pay. You may have a base salary, a draw, or commission only. Go to the guide for employees.
If you get a 1099
Two different laws apply, depending on what you sell. The guide for independent reps sorts that out.
If you get a 1099 but the company runs your day
Set hours, set prices, a required CRM, no freedom to sell for anyone else: you may be an employee no matter what the paperwork says. Start with "Am I really an independent contractor?"

Five things every New York salesperson should know

  1. An earned commission is a wage. For an employee, it has the same protection as a paycheck (Labor Law § 190(1)). For a contractor, it is a debt the company owes. Either way, the company cannot simply keep it.
  2. What you did, and when, usually decides the case. A commission is generally earned when your sales work is done, with or without a written plan. A deal you completed before leaving is yours even if the customer pays later (Pachter; Arbeeny).
  3. A plan cannot forfeit a commission you already earned. Parties are "not free to enter into contracts which violate public policy," so earned wages cannot be contracted away (Weiner).
  4. The law requires a writing. Employers must give commissioned employees a signed written plan (§ 191(1)(c)). Wholesale reps are entitled to a written contract (§ 191-b). Most other freelancers earning $800 or more are too.
  5. Some deadlines are short. 180 days to put company owners on notice. Two years for retaliation, and for a freelancer's missing-contract claim. Six years for most New York wage claims.

The cases

Every decision cited in this guide is here in full, with its complete citation and a free PDF marked with official reporter page numbers, so you can quote a passage and cite it the way a court does.

Browse the case library

This page is general information about New York and federal law, last reviewed September 2026. It is not legal advice, and reading it does not create an attorney-client relationship. Dollar figures and deadlines change. If a deadline may be close, speak with a lawyer now.