Gig work

Misclassification

Also called: worker misclassification, 1099 misclassification

A business treating a worker as a 1099 independent contractor when they should be a W-2 employee — illegal, and a growing enforcement focus.

Misclassification happens when a business treats a worker as a 1099 independent contractor when the actual working relationship meets the legal definition of W-2 employment. Misclassification denies the worker:

  • Employer-paid half of FICA (7.65%)
  • Minimum wage and overtime protections
  • Unemployment insurance coverage
  • Workers' compensation
  • Eligibility for employer-sponsored benefits

And it lets the business avoid:

  • Payroll tax matching
  • Unemployment insurance contributions
  • Workers' comp premiums
  • Minimum wage / overtime liability

Tests used to determine proper classification:

  • IRS common-law test: behavioral control, financial control, relationship
  • FLSA economic reality test: integration with the business, profit/loss opportunity, investment in equipment, skill required, permanence, control
  • ABC test: stricter, used by 24+ states for unemployment determinations and (in CA) for most labor law purposes

If you believe you're misclassified, you can file Form SS-8 with the IRS for an official determination, Form 8919 to recover the uncollected FICA on past wages, or a complaint with state DOL / federal Wage and Hour Division.

The 2024 federal DOL rule restored a stricter "totality of the circumstances" test for federal classification, making it harder for businesses to classify ongoing workers as ICs.