California AB 5 Construction Subcontractor Exemption (Labor Code § 2781) & $600 FTB 1099-NEC Rule

Under California Labor Code § 2781, construction subcontractors can qualify as independent contractors only if they hold an active CSLB license, operate a separate business entity, and have a written contract, and California FTB still mandates Form 1099-NEC filing at $600 even though the federal threshold is $2,000.

Open 2026 $2,000 vs. $600 1099 & W-9 Reconciler

2026 Compliance Checklist

• Collect Signed Form W-9 Before First Disbursement: Never release a check, ACH, or Zelle payment without a signed W-9 on file, or deduct 24% IRC § 3406 backup withholding.
• Separate IRC § 6050W Card/TPSO Payments: Exclude Stripe, Square, and credit card payments from Form 1099-NEC Box 1.
• Verify State $600 Non-Conformity: Even if a vendor was paid between $600 and $1,999 in 2026 (exempt federally under OBBBA § 70432), verify whether your state still mandates a $600 state 1099 filing.