Focused Solution: Fashion Workers Act Compliance for Agencies

A New Phase for Model and Talent Agencies

On June 19, 2025, the New York Fashion Workers Act (FWA) went into effect, establishing critical protections for models and new responsibilities for model management companies and their clients in New York State. The Act mandates registration, contract transparency, payment timelines, fiduciary duty, and oversight of digital replica usage—among other sweeping reforms.

For agencies, complying with these legal and financial requirements means upgrading operations with systems that support not just talent bookings and client relationships, but compliance through communication, documentation, and transparency. The FWA will be enforced starting one year later, on June 19, 2026, giving agencies a little time before potential penalties could be assessed for non-compliance…

Though the FWA only effects New York City and State for now, there are similar laws being considered in other regions and markets, so any model or talent agency could consider the FWA as a set of operational “best practices” guidelines, which can be used to optimize the business now and prepare for the future.


Photo by cottonbro studio on Pexels

Key requirements under the Fashion Workers Act include:

  • Agency Registration & Bonding with the NY Department of Labor
  • Commission Limits (20% max) and full disclosure of financial relationships
  • Timely Deal Memos issued 24+ hours before engagements
  • Payment Oversight including overtime, breaks, and transparent deductions
  • Consent Requirements for AI-generated likenesses or explicit content
  • Fiduciary Duties to models, including detailed recordkeeping and accountability

Noncompliance can result in steep penalties, legal action, and reputational damage. Meeting these obligations isn’t just about awareness—it requires the right systems to ensure compliance at scale.


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CKS Cloud Solutions is not a legal services company, but we understand the Fashion Workers Act very well after participating in legal reviews and compliance discussions with our agency clients. We have worked closely with both legal teams and agency professionals to ensure that our software and services support the accounting, financial, and reporting requirements of the law.


Photo by cottonbro studio on Pexels

CKS helps model, talent, and artist agencies maintain FWA compliance on the financial and operational side by delivering and supporting:

✅ Accounting & Payroll Systems Built for Compliance

  • Enforces commission caps, standard deductions, and fiduciary accounting best practices
  • Supports detailed reporting on client payments, model earnings, and agency fees
  • Aligns financial systems with overtime, per diem, and meal break requirements

✅ Model & Client Transparency

  • Real-time access to reports, invoices, and payment status
  • Configurable dashboards to support client audits or internal reviews
  • Audit trails for deductions, consents, and deal terms

✅ Integrated Deal Memo & Financial Tracking

  • Captures deal terms and final client agreements for accurate downstream financials
  • Links booking data to payment processes to ensure traceability and audit readiness

✅ Partner Integration with Booking Systems

CKS partners with FWA-compliant booking platforms, including Booker by FineLab, which supports:

  • Time-stamped deal memos with 24-hour review windows
  • Digital consent tracking for AI likenesses or sensitive content
  • Model-facing portals with booking details and fee breakdowns

Together, CKS and Booker deliver an end-to-end solution for agencies that want both operational agility and regulatory confidence.


Photo by cottonbro studio on Pexels

CKS has served the fashion, modeling, and creative talent industries for over 20 years. Our ERP and financial systems are used by agencies that book thousands of jobs each year, manage diverse global talent, and need to meet a growing list of compliance demands. By staying close to the evolving legal landscape—and working directly with industry clients and their legal advisors—we ensure our systems are ready for what’s next.


Photo by Rômulo Carolino on Pexels

The Fashion Workers Act is more than a regulatory milestone—it’s a call for transparency, accountability, and professionalism in the agency, marketing, and advertising workforces. Agencies that modernize their back-office operations with CKS Cloud Solutions can:

  • Confidently manage compliance on the financial side
  • Maintain audit-ready records and fiduciary transparency
  • Integrate seamlessly with best-in-class booking systems like Booker
  • Protect their talent and reputation with systems that scale

CKS Cloud Solutions delivers the technology agencies need to thrive in the FWA era—so you can focus on creative excellence while we help take care of the rest.


Tell us where you want to go, and we’ll take you there!

CKS // Cloud Solutions

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