Priority Industry

AB 5 Compliance for Tech Startups: Dev, Design, and Marketing Contractors

Tech companies routinely engage developers, designers, marketers, and fractional executives as contractors. California's AB 5 creates unique challenges for these arrangements, especially when contractors are deeply integrated into daily operations. This guide covers integration risk patterns, Prong B analysis for tech, B2B exemption requirements, and compliant structuring options.

The Tech Integration Trap

Key Risk: Tech companies often give contractors company email, Slack access, daily standups, and treat them as "part of the team." This integration evidence can override even perfect contracts. The more a contractor looks and acts like an employee, the more likely they ARE an employee under AB 5.

Integration Risk Patterns

These patterns signal employee status regardless of contract terms:

@ Company Email Address

Giving contractors @yourcompany.com email suggests they represent your company. Use their own email or a clearly labeled external domain.

# Full Slack/Teams Access

Unlimited access to internal channels, @all notifications, and team discussions integrates contractors into company operations. Limit to project-specific channels only.

S Daily Standups Required

Mandatory daily meetings indicate schedule control (Prong A). Occasional project check-ins are fine; required daily attendance is an employment indicator.

T Internal Ticketing Systems

Assigning work through Jira/Linear tickets like employees suggests task-level control. Better: project-based SOWs with contractor managing their own task breakdown.

P Sprint Participation

Including contractors in sprint planning, retrospectives, and team velocity tracking treats them as team members, not independent service providers.

L Company Laptop/Equipment

Providing equipment suggests economic dependence and control. Independent contractors typically provide their own tools and equipment.

Prong B Analysis for Tech

When is dev/design work "within your usual course of business"?

Your Company = Software Product

If you sell software: Developers building your product likely fail Prong B. The work IS your business. A SaaS company hiring dev contractors to build features is having them work within its usual course of business.

Your Company = Non-Tech Service

If you sell non-tech services: Dev contractors may pass Prong B. A law firm hiring a contractor to build its website has a different "usual course" (legal services). But ongoing product development blurs this line.

The "Core vs Support" Question

Key analysis: Is the contractor's work integral to what you sell, or truly ancillary? A fintech's mobile app developers = core. A retailer's website contractor = likely ancillary. But line is often unclear for tech-enabled businesses.

Marketing and Design

Marketing agencies fail Prong B when hiring marketing contractors. Non-marketing companies hiring marketing help may pass Prong B but must still pass A and C. Same analysis for design: design agencies vs. companies using design contractors.

Common Tech Contractor Scenarios

Offshore Dev Team

Lower Risk

Developers located outside California (and outside the US) are generally not subject to AB 5. California wage orders apply to work performed in California.

  • Key factor: Physical location of work, not company HQ
  • Risk: If they occasionally work from California, AB 5 may apply to that work
  • Best practice: Contracts should specify work location and applicable law

Agency Subcontractor

Medium Risk

Hiring an agency (LLC/Corp) that provides developers. The agency is your contractor; their devs are the agency's classification problem.

  • B2B exemption potential: Genuine business-to-business relationship may qualify
  • Risk: If agency is a pass-through (single contractor using LLC), may be pierced
  • Key factor: Does the agency have multiple clients, employees, real business operations?

Fractional CTO/VP Engineering

Medium Risk

Part-time executive contractors are common in startups. May qualify for professional services exemption if properly structured.

  • Professional exemption: Requires advanced degree or professional license in specialized field
  • Key requirements: Own business, multiple clients, controls manner of work, earns >2x minimum wage
  • Risk factor: Deep integration, company email, management authority looks like employment

Full-Time Contractor (40hr/week)

High Risk

Contractor working 40 hours exclusively for your company. Despite "contractor" label, this arrangement often fails all three prongs.

  • Prong C problem: Full-time exclusivity = no independent business indicators
  • Economic reality: If they depend on you for all income, they're economically dependent
  • Recommendation: This should probably be employment. The cost savings aren't worth the risk.

Project-Based Marketing/Design

Lower Risk (if structured right)

Designer or marketer engaged for specific project (rebrand, campaign, website) with defined scope and timeline.

  • Prong B: Often passes if your business isn't marketing/design
  • Key factors: Fixed project scope, contractor controls methods, has other clients
  • Risk: "Ongoing projects" that become continuous engagement lose project-based protection

B2B Exemption Requirements

The business-to-business exemption (Labor Code 2750.3(e)) may allow IC classification if ALL requirements are met:
Requirement What It Means Evidence Needed
Business entity exists Contractor has LLC, Corp, or sole proprietorship Business license, EIN, formation docs
Provides services directly Entity (not individual) is the contracting party Contract with LLC/Corp, not individual
Written contract Contract specifies services, payment terms Signed MSA and SOW
Actual control over work Contractor determines how to perform services No method instructions, outcome-based deliverables
Customarily engaged Contractor provides this service to multiple businesses Other clients, marketing, public-facing business
Bona fide business Real business operations, not just for you Website, insurance, equipment, business location
Work outside hiring entity's place of business Contractor doesn't work at your office Remote work, contractor's own workspace
Sets own rates Contractor determines their pricing Contractor's rate card, negotiated rates
Can work for competitors No exclusivity or non-compete restrictions Contract allows other clients including competitors
Important: ALL requirements must be met. Missing even one disqualifies the exemption and requires ABC test analysis. This is why "contractor with LLC" alone isn't sufficient.

Compliance Paths for Tech Companies

Path 1: Employee Classification

Accept that California-based, deeply-integrated, core-function workers are employees.
  • Full integration OK (Slack, standups, company email)
  • Direct task assignment and supervision OK
  • Higher cost but zero misclassification risk
  • Required: payroll taxes, workers comp, benefits
  • Best for: core product devs, ongoing roles

Path 2: True IC (B2B Exemption)

Structure relationship to meet B2B exemption requirements.
  • Contract with LLC/Corp, not individual
  • Project-based SOWs, not ongoing work
  • No company email/Slack, minimal integration
  • Contractor has other clients
  • Best for: agencies, specialists, short projects

Integration Reduction Checklist

If keeping IC classification, reduce integration signals:

Documentation Requirements

For B2B IC Relationships

  • Master Services Agreement - B2B terms, both parties as businesses
  • Statement of Work - Project scope, deliverables, timeline, price
  • Contractor evidence file - Business license, insurance cert, other clients
  • Invoice records - Business invoices, NET payment terms
  • IP Assignment - Work-for-hire or assignment provisions

For Employee Relationships

  • Offer letter - At-will, California-compliant terms
  • PIIA - Proprietary Information and Invention Assignment
  • Handbook acknowledgment - Policies, at-will, etc.
  • I-9, W-4 - Employment eligibility, tax withholding
  • Arbitration agreement - Optional but recommended

Tools and Resources

ABC Test Classifier Tool - Analyze Your Model IC vs Employee Cost Calculator B2B Exemption Checker Borello Factor Analyzer Back to AB5 Hub

Get Expert Legal Guidance

Tech contractor relationships require careful structuring. Get: (1) Classification analysis for your specific arrangements, (2) B2B exemption qualification review, (3) Compliant agreement drafting (MSA/SOW or employment docs), (4) Integration audit recommendations.
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