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U.S. compliance for executive coaches

U.S. compliance for executive coaches

ComplianceKaro Team
January 3, 2026
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U.S. compliance for executive coaches

Business formation & registration - Form an appropriate business entity (LLC, S-corp, or other) based on liability and tax goals; register with the state where you operate and obtain an EIN for tax reporting and banking.

Maintain operating agreement, up-to-date state filings (annual report/fees), and local business licenses where required. 2) Federal tax obligations (IRS) - Coaches operating as sole proprietors or single-member LLCs generally report income on Schedule C and pay self-employment tax (Social Security & Medicare).

Obtain EIN, keep accurate records, and file required forms (1099-NEC for contractors you pay; W-2s and payroll filings if you hire employees). The IRS small-business center is the central resource for forms and filing requirements.

Business formation & registration

2) Federal tax obligations (IRS) - Coaches operating as sole proprietors or single-member LLCs generally report income on Schedule C and pay self-employment tax (Social Security & Medicare). Obtain EIN, keep accurate records, and file required forms (1099-NEC for contractors you pay; W-2s and payroll filings if you hire employees).

The IRS small-business center is the central resource for forms and filing requirements.

  • Form an appropriate business entity (LLC, S-corp, or other) based on liability and tax goals; register with the state where you operate and obtain an EIN for tax reporting and banking. Maintain operating agreement, up-to-date state filings (annual report/fees), and local business licenses where required.

Worker classification (DOL / federal guidance) - Carefully classify assistants, subcontractors, or associate coaches as independent contractors vs employees using federal tests and factors — misclassification can trigger back payroll taxes, penalties, and wage claims. Maintain written agreements and document control over how services are performed.

Contracts, engagement letters, and scope-of-practice - Use written coaching agreements that define

coaching vs therapy boundaries, confidentiality, limits of services, fees, payment/cancellation/termination terms, deliverables, and dispute resolution. ICF emphasizes co-creating a coaching agreement and clear disclosure of roles and responsibilities. If offering assessments, mental-health-adjacent services, or regulated activities (psychotherapy, diagnosis), disclose limitations and refer to licensed professionals as required by state practice laws.

Professional standards & ethics (ICF) - If you are ICF credentialed or represent yourself according to ICF standards, follow the ICF Code of Ethics

agreements with clients/sponsors, confidentiality and legal compliance, conflict-of-interest management, accurate representations of credentials and outcomes, and recordkeeping/privacy obligations. ICF also provides an Ethics Assist Line and an Ethical Conduct Review process for credential holders.

Advertising, testimonials, and endorsements (FTC) - Advertising and marketing claims must be truthful and substantiated. If you use testimonials, endorsements, or influencer-style marketing (including client success stories), comply with the FTC Endorsement Guides and disclose material connections. The FTC updated guidance (including Endorsement Guides revision in 2023 and rules on consumer reviews/testimonials) is directly applicable to online marketing and social media.

Data privacy & confidentiality (state privacy laws example

CA CCPA/CPRA) - Coaches collect sensitive personal information (contact details, business metrics, sometimes mental-health information). State privacy laws (e.g., California’s CCPA/CPRA) create consumer rights (access, deletion, opt-out) and obligations for businesses that meet thresholds. Even if not subject to CCPA thresholds, adopting privacy policies, limited data retention, secure storage, and client consent/disclosure practices is best practice. Maintain confidentiality clauses, secure electronic records, and vendor/data-processing agreements when using cloud tools.

Insurance and risk management - Commercial general liability and professional liability (E&O) insurance are recommended. E&O can cover claims of negligence or mistakes in professional services. Verify policy terms for coaching-specific exposures.

State-specific considerations - Most states do not license “coaching” as a distinct profession, but states do regulate psychotherapy and counseling — coaches must avoid practicing therapy without appropriate licensure. State consumer protection laws, business registration requirements, sales tax rules on professional services, and privacy laws vary by state; verify the rules where you and your clients are located.

Recordkeeping and compliance practices - Keep financial records (income, expenses, receipts) for tax periods, retain coaching records per your privacy policy and applicable laws, document coaching agreements and informed consents, and maintain proof of client authorizations for recording sessions or sharing testimonials.

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