Salon booth renters and the 1099 line in Minnesota
Do Minnesota salons owe employment duties to booth renters?
Renting a booth is a license question first
A booth renter is not a junior employee by default, but the arrangement only works if the licensing paperwork is straight on both sides.
Minnesota law says a person must not offer cosmetology services for compensation unless the services are provided by a licensee in a licensed salon. The renter needs their own practitioner license, and the chair needs to sit under a salon license somewhere.
A salon with employees needs more than the license. The salon licensing statute asks, where applicable, for evidence of compliance with the workers' compensation law for salon workers, and for professional liability insurance of at least $25,000 per claim and $50,000 per policy year for each operator.
Minnesota Statutes 155A.29 provides that a person must not offer cosmetology services for compensation unless the services are provided by a licensee in a licensed salon. — Minnesota Revisor of Statutes, retrieved 2026-09-29
$25,000 per claimMinnesota Statutes 155A.29 conditions salon licensing on workers' compensation compliance where applicable and liability insurance of at least $25,000 per claim and $50,000 per policy year. — Minnesota Revisor of Statutes, retrieved 2026-09-29
Suite salons pick one of two structures
Suite-style buildings have exactly two lawful shapes under the board's rules, and they decide who holds the salon license.
Minnesota Rules 2105.0397 states it flat: suite-style salons must have one salon license under which every suite on the premises operates, or each suite must carry its own salon license as an individual salon. A landlord-salon license covering the whole floor is one route; every renter licensing their own suite is the other.
The choice moves money and duties. One building license concentrates the salon-law obligations with the business leasing the suites. Suite-by-suite licensing pushes them to each renter, each at the published salon license fee rather than one shared.
Minnesota Rules 2105.0397 requires suite-style salons to hold one salon license covering every suite, or a separate salon license for each suite. — Minnesota Revisor of Statutes and Rules, retrieved 2026-09-29
What the licenses cost, on the board's own schedule
The fee schedule is three-year, published in the statute itself.
An initial practitioner, manager or instructor license costs $195, and renewing a practitioner license costs $115. A salon's initial license costs $350, and its renewal costs $225. Renters renewing on time avoid the late fees, which the same schedule lists, and every renewal asks for continuing education credits under a separate section.
The numbers matter for the hiring choice as much as the renting one. A renter's own license stack is their own cost; an employee's practitioner license still has to exist, but the salon can lawfully build its staffing model around either.
| License | Initial fee | Renewal fee |
|---|---|---|
| Practitioner | $195 | $115 |
| Manager or instructor | $195 | $145 |
| Salon | $350 | $225 |
| Practitioner late renewal | — | $45 added |
| Salon or school late renewal | — | $50 added |
$350 initial salon licenseMinnesota Statutes 155A.25 sets three-year fees of $195 initial and $115 renewal for practitioners, and $350 initial and $225 renewal for salons. — Minnesota Revisor of Statutes, retrieved 2026-09-29
4 hours per 3 yearsMinnesota Statutes 155A.271 requires four hours of board-approved continuing education in the three years before renewal, plus a four-credit-hour scope-of-practice course. — Minnesota Revisor of Statutes, retrieved 2026-09-29
The penalty rows aimed at independent-operator labels
Cosmetology is the rare trade where the fee schedule names the 1099 question directly.
The statute's penalty list includes two rows that do not exist in any other trade's fee schedule: an owner and manager allowing an operator to work as an independent contractor, at $200, and an operator working as an independent contractor, at $100. Read them against the suite rule above: a renter is an independent business carrying a license, and an "operator" who is not is someone the salon is treating as an independent contractor without the structure that makes it lawful.
A salon owner who calls employees "booth renters" to skip payroll meets exactly these rows, plus the general misclassification penalties on the penalties page. A genuine suite licensee renting a station does not.
$200Minnesota Statutes 155A.25 lists a $200 penalty for an owner or manager allowing an operator to work as an independent contractor, and $100 for the operator. — Minnesota Revisor of Statutes, retrieved 2026-09-29
How the classification tests treat a chair
Cosmetology is not construction, so the fourteen-requirement construction test never applies. The general test does, and it is the five-factor common-law weighing described on the classification guide.
A renter with their own practitioner license, their own prices, their own client book and their own supplies clears the factors the way any specialist does. A stylist the salon schedules, trains, prices and pays a split to fails them the same way a helper on any other crew would.
The trade's own rules sharpen the line further. A renter who does not hold a salon license is renting in a licensed salon and must meet the board's advertising rules, advertising under their own licensed name or naming the salon. When a salon starts collecting the rent as a percentage and dictating the books, the arrangement drifts from rent toward employment, and the drift is measurable.
Minnesota Rules 2105.0110 requires a practitioner renting salon space who advertises under a business name to list their full licensed name, or name the salon. — Minnesota Revisor of Statutes and Rules, retrieved 2026-09-29
Decide the model before the first chair is filled
Both models are lawful; half-and-half is what the penalties are for.
Renting: the renter holds a current practitioner license, the building holds or the renter holds the salon license, the rent runs at a fixed rate, and the renter keeps their own prices and clients. Employing: the salon licenses, schedules, trains and pays the stylist, carries workers' compensation, and withholds payroll tax.
Whatever the mix, put each arrangement in writing and keep the records. The checklist page lists the papers, and the workers' comp page covers when coverage is owed either way. If a stylist is on your books as a renter but takes your schedule, the day to fix that is before an inspection, not after.
Minnesota Statutes 176.041 lets a salon hiring an independent contractor elect workers' compensation coverage for that contractor. — Minnesota Revisor of Statutes, retrieved 2026-09-29
Questions
Can I pay my stylists as 1099 contractors instead of employees?
Only if each one genuinely runs their own business under the five-factor test, and the cosmetology rules are satisfied on top. A stylist you schedule, price and pay a split to is an employee. The fee schedule carries its own penalty for calling an operator an independent contractor, $200 for the owner and manager and $100 for the operator.
Does my booth renter need their own salon license?
Not necessarily. A suite-style salon can operate under one salon license covering every suite, or each suite can carry its own salon license. A renter without their own salon license rents inside a licensed salon and must follow the advertising rules that name the salon.
Whose workers' compensation covers a booth renter?
A genuine independent business is excluded from the workers' compensation chapter by statute, though coverage can be elected for an independent contractor you hire. A mislabeled employee is covered, and the salon can owe the coverage it never carried, plus penalties.
Do salon licenses renew every year like LLCs do?
No. Cosmetology licenses run on a three-year cycle, while a Minnesota LLC files an annual renewal with the Secretary of State by December 31. Two different calendars, both worth a recurring reminder.