Campaign Staff Classification: The “1099 vs. W-2” Decision Matrix 

Table of Contents

Written By

Campaign Staff Classification: The “1099 vs. W-2” Decision Matrix 

Subject: Legal Risk Assessment – Worker Classification Protocol

To: Campaign Leadership, Finance Team, Legal Counsel
From: AccuPay Systems – Political Payroll Division


The Warning:
Misclassifying campaign workers is the fastest way to bankrupt your campaign—not from losing the election, but from Department of Labor (DOL) lawsuits.

In the political world, there is a dangerous myth that
“everyone is a consultant until we win.” This is false.

If you hire 20 canvassers, hand them campaign iPads, tell them where to walk, and pay them hourly, they are
W-2 Employees—not Independent Contractors.

Getting this wrong exposes the candidate to class-action lawsuits for unpaid overtime, back taxes, and penalties that can haunt them long after Election Day.


Action Required:
Use this decision matrix to classify every single person on your payroll.

The Decision Matrix: Employee (W-2) vs. Contractor (1099) 

Decision Factor W-2 Employee (The Staffer) 1099 Contractor (The Consultant)
Behavioral Control Campaign dictates how work is done.
  • “You must knock doors Mon–Fri, 12pm–8pm.”
  • “You must use this specific script and app.”
  • “You must wear this campaign t-shirt.”
Worker decides how to achieve the goal.
  • “Deliver a polling report by Friday.”
  • “Design a mailer.”
  • Works on their own schedule and methods.
Financial Control Paid by the hour or salary.
  • Campaign reimburses gas/mileage.
  • Campaign provides equipment (phones, iPads).
Paid by the job or flat retainer.
  • Pays their own expenses.
  • Uses their own laptop/software/camera.
  • Can lose money if the job goes wrong.
Relationship “At-Will” Employment.
  • Expectation of work until Election Day.
  • Integral to daily operations (e.g., Field Organizer).
Project-Based.
  • Hired for a specific task (e.g., “Shoot one TV ad”).
  • Works for multiple campaigns simultaneously.
Training Campaign trains the worker.
  • “Here is how we talk to voters.”
  • Mandatory orientation/onboarding.
Worker brings the expertise.
  • You hired them because they already know how to poll, design, or film.
Typical Roles
  • Field Organizers
  • Canvassers
  • Campaign Manager
  • Finance Director
  • Media Buyer
  • Pollster
  • Graphic Designer
  • Direct Mail Firm

The “Canvasser Trap”: A Specific Warning

The most common compliance failure in modern campaigning is hiring Canvassers as 1099 Contractors. 

  • The Scenario: You hire 50 students to knock on doors for $15/hour. You treat them as contractors to avoid paying Social Security, Medicare, and Unemployment taxes. 
  • The Reality: Because you control their routes, scripts, and hours, the DOL considers them employees. 
  • The Risk: If one canvasser files a complaint about unpaid overtime (working >40 hours in a chaotic GOTV week), it can trigger a class-action audit for all 50 staff members. 

The Rule of Thumb: If they are “boots on the ground” taking orders, they are W-2. If they are “experts in the office” giving advice, they might be 1099.

Why This Matters for FEC Reporting

Your classification affects your FEC disbursements. 

  • W-2 Staff: Reported as “Payroll” or “Salary.” The campaign pays the employer share of payroll taxes (approx. 7.65% + Unemployment). 
  • 1099 Consultants: Reported as “Consulting Services.” No taxes withheld. 

AccuPay Insight: Consistency is key. You cannot pay a Finance Director as a “Consultant” for three months and then switch them to “Payroll” without raising eyebrows at the FEC or IRS. Pick a lane and stay in it.

Enter your email to download

Your download will start as soon as you submit your mail.