Ask HN: Freelancer's Dilemma – Client Won't Pay Despite Clear Agreement

94 points by alexliu518 ↗ HN
Hi HN,

I'm a freelancer working on various software development projects through different platforms. Recently, I completed a significant project for a client outside of these platforms, and they're now refusing to pay the final invoice. Despite having a clear written agreement and delivering everything as agreed, they're ignoring my emails and calls.

Has anyone here faced a similar situation? How did you handle it? Any advice on legal actions, or ways to secure payment upfront in future projects? Appreciate any tips or resources that could help!

Thanks in advance!

150 comments

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Can your client actually pay? If not pursuing legal actions will just be a waste of money.

In general breakdown payment for larger projects into smaller installments / subprojects.

Have they given any reason for not paying or disputed the invoice in any way? Which jurisdiction applies to the agreement? Many jurisdictions have fastlane procedures for collecting on undisputed claims that you might be able to use.
IANAL but I would have a lawyer send a letter to their CEO.
Lawyers are generally worth their rate just for access to their letterhead.
Use it as a learning experience and move on. I use only hourly billing, that way I get paid and customer sees continuous progress.
The best advice in this common mal practice is setting as base law court your jurisdiction; the farer the better.

For instance, I am in Spain and I always signed contracts based in California, etc. Badly done! Next time I will set Madrid, Spain courts as ruling law.

This way you can sue the ass off them and make them pay the money in debt and even some more to the courts.

edit: typo

Unfortunately that will probably not do you much good. If the company is based outside of Spain all the Spanish courts can do is take their assets located in Spain which is probably nothing.
Spain is a bad example, but lots of countries have bilateral legal arrangements for this sort of thing.
As Spain is part of the EU, it should at least be good for the EU.
All assets in the EU now and for the next 1000 years.
That's an interesting statutes of limitations. 1000 years. That will outlast all governments in Europe if the past is any indicator.
It's just convenient to measure things in Reichs...

(I need a less controversial sense of humour. I should run it through chatgpt first.)

Edit: ran it through Google Gemini. Wow, I suck!

"The response "It's just convenient to measure things in Reichs.." is highly inappropriate and offensive."

Sorry my AI friends!

Doesn't that make it easier for a California company to just ignore you?
No it just means that they need to appear in your courts via a local law firm if they want to contest.

This is good advice.

Or they can just totally ignore the lawsuit with absolutely no repercussions.
An example from my experience.

Due to one of these civil law agreements.

We attained an enforceable undertaking based on the contract here.

Then we began proceedings to convert that to whatever the same thing was over there.

Which is when the other parties legal representation decided that it was a real threat and they settled.

How will the Spanish court enforce their decision abroad? I know there are agreements between te countries, but what happens practically after a decision? Who gets activated in the US to enforce the decision?
You can take the judgement to a US court and it will be a simplied process. As long as it is a "normal" country like spain it shouldnt be a problem (if the court was say an Iranian court it might be more difficult).
Most courts will see a contract from anywhere and enforce it (Super Generally)

Most courts will see a contract + an enforceable undertaking from the country whose laws it was signed under and see that as roughly enforceable.

Doesnt mean always.

Might be a pain. If they have any EU presence, it'd be easier.
Good answer and better question: Do civil law can enforce itself without bilateral agreements initiaing a claim to a foreign court? I don't think so. Even criminal couts can't without agreement.
Without agreements you go ahead and win your local case and then hope that the contract is enforceable in their country.

Thing is torts are very similar all over the place. Like if you are a former british colony your laws are usually roughly compatible. Most countries dont have a "contract was signed overseas fuckem" law. But some do.

No delivery of code until paid in full. Demo on servers you control.
Always have a contract, even for smaller bits of work. That’s the foundation of a good business relationship.

If they have the money to pay, but are ignoring you then escalate from your contact at the company to someone higher in the chain. If that doesn’t work and it’s a relatively small amount of money then you can try to enforce the contact.

I’m in the UK and there’s a small claims court for specifically this. I’ve not gone through it myself but from those that have it’s simple enough to do yourself without paying a lawyer, but it’s time consuming. Im not sure where you are but look into if there’s in in your jurisdiction.

If the client likely doesn’t have the money to pay, then it’s likely a waste of time to pursue it. I had this happen recently when a client went under and ended up just writing it off as a loss. Luckily it was only my time that was wasted so not the end of the world.

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Having done freelance work with customers in different countries (US mostly but France, Japan, China and UK). Americans are not more likely to screw you over than companies in other countries.

But yes, the rest of advice is good. Also when it comes to contract, do be careful about IP rights (more for the customer than the freelance). I've seen some customers get screwed by not clearly stating that the freelance employee transfers their IP right.

The “Americans suck” line undermines the credibility of everything else you said. Why bother to give sober-sounding advice if you are going to puke all over your own words at the very end? It’s just childish.
I am an American. I have worked with other Americans and with clients in 25 other countries. I have been in business for 25 years.

There is no evidence, from my experience, to support the contention that ANY country "sucks" to work with. Some countries are annoying about taxes, but that's not a cultural issue.

The United Arab Emirates can be tricky to get into. Don't break the law while you are there. But they are used to skilled foreign workers, and treat them well.

I no longer go to China. The Internet situation (and political situation) is not good, there. Also, their English is not good enough, for my needs. But I still wouldn't say they "suck" to deal with.

What country/state are you from, what country state is your client from and how much money are we talking about? In the US there is a fairly straightforward process to sue someone in small claims court without a lawyer and with fairly small fees. But small claims courts are limited to small awards.

I have not worked as a freelance programmer nor hired any, but a friend really likes to hire freelancers for various projects and often asks me for advice and tells me about his travails. I think practically speaking, it is not that hard for a freelancer to get paid because software always needs upkeep for bugfixes or updates to work with other software or to add new features. And it is far far far more expensive to have a second freelancer look at the first freelancers code and do the updates.

Some people say it takes more time to read code than to write it. I am not sure if that is true but very often if you ask a second freelancer to do minor updates on another freelancers code, the second guy will just say that the code is so awful the whole thing has to be rewritten from scratch. So you have a big advantage just by having written the stuff and having the code in your head and written in your style. You are the best man to fix it and update it by far.

My friend always pays his bills but he is a very tough negotiator, and often gets comparatively good bargains for freelance work. However, all the benefits of his bargains disappear when he needs the software to be changed a bit in six months or so. Then the freelancer is in the drivers seat and my friend completely drops his tough negotiator stance and becomes super nice and friendly towards the freelancer.

So if you do not want to pay for lawyers and small claims court is not suitable for some reason, you may just send a demand letter saying that you are charging a 20% penalty for non-payment and interest will accrue in the future, and just wait for your client to need some update and then you demand that all previous invoices be satisfied before discussion for new work even begins.

IANAL, this is not legal advice. If the sum is a large amount, it would probably be best to consult a lawyer.

Man that sucks. My advice is, do everything in your hand from a legal perspective - consult a lawyer, it should be free - show them you're serious about your work.

If you still have no answer, expose them! Write a blog or an article about their malpractice. Publish the code you wrote for them if you can. Perhaps, that will draw their attention.

Put an equal amount of effort in proportion to the amount of money you're owned. If your effort becomes too great, drop it and spend your time elsewhere.

In addition to the advice that's given here, make sure you detach yourself from both the process and the outcome as soon as possible.

After you had your lawyer send them an angry letter (twice) and you haven't got your money after two months, you need to emotionally accept that the money is likely gone, and make sure that you are mentally capable of focusing on ensuring your financial stability.

Either set an automated mail to remind them what they owe if it's a small amount of money (i.e. less than 5k) and if it's more ask your lawyer if they or someone they know can handle the case on a fixed price basis.

And then move on. Non paying clients absolutely suck. I haven't had one that didn't pay at all (though some very late payers), but I've had friends tell stories and it can wreck your freelance experience. If you let them get to you then you'll lose the feeling of freedom and all advantages of freelancing. Accept that it's part of the game and account for it in your financial planning. If you don't the stress will eventually kill all enjoyment of being a freelancer.

(Btw, I don't mean give up. Just dissociate from the outcome. If the only fee your lawyer would take is 100%, still do it to f with the lousy client.)

In Russia, if it is a foreign client, the OP would have been fined by the government for the amount that the client owes him, now that the OP publicly admitted the non-payment. This is done because there was a tax evasion scheme based on allegedly-unpaid invoices from foreign "customers". So it is already 300% of losses (100% due to the unpaid debt plus 100% from the fine plus 100% from the lawyer).
In Russia, they'd be using an offshore entity for billing anyway :)
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They actually gas the hostages.
> tax evasion scheme based on allegedly-unpaid invoices from foreign "customers".

Care to elaborate?

Maybe you can deduct unpaid invoices from your business income. Get enough of those and you don't owe any taxes. And if the government tries to figure out why your client isn't paying, they can't because they're foreign.
I've recently dealt with this over a 8 month period, and it was mentally exhausting. I wish I would’ve just accepted the money to be lost, and let a lawyer deal with it, but instead spend 8 frustrating months trying to deal with it.

In the end I lost far more money than just what my client owed me. For months I couldn’t focus on work, and just wasn’t mentally able to find new clients.

I think, even if you pass it over to a small claims process, setting timelines helps here.

For example, send a demand letter with a response time. Typical is to give a couple of weeks or some such.

Then set an alarm in your phone's calendar and drop it from mind.

Treat it as any other deliverable. And if you can do small claims court, even better. Typically no lawyers allowed, amd again, you file and serve, then set a calendar.

“No lawyers allowed” isn’t likely to be the case if you sue a corporation or other business association, which by law in my state at least may not be represented by an individual unless that individual is an attorney.

That being said I have not sued a corporation in small claims court so I’m not really sure who would show up.

At least for me, the worrying would never stop. Even when I send letters with clear deliverables and timelines, I would just find myself worrying and getting angry over the whole situation.

The only time it stopped was after about 7 months, when we finally signed a settlement agreement. But then it all started again when no payment came in.

I’m not sure how the other party felt about all this, but to be on the receiving end of it all is horrible, and maybe just accepting the money is lost would’ve been better in the end.

I've had this too.

Be pragmatic and move on (mentally), and don't make it personal nor seek revenge. I'm sure it would be tempting to make them suffer like you have, but if doing so will make you worse off then you already are (be it financially or emotionally), what's the point.

Accept the base line outcome is zero, don't make it less than that and anything extra is a bonus.

Persue it, dispassionately but persue it, not for revenge but for the good of everyone else including your own future self.

It is not long term thinking to to just absorb such things in my opinion. It must cost the perpetrator enough that the most selfish unprincipled business animal decides that even for purely selfish reasons, they gain the most by avoiding triggering such suits.

It's a duty.

In the UK that would be very simple. Send statutory demand, let's say give 21 days to pay and tell the company if they don't you'll file a winding-up petition to the court (basically if company can't pay its debts it will be closed).

Usually then company pays straight away.

>you need to emotionally accept that the money is likely gone, and make sure that you are mentally capable of focusing on ensuring your financial stability.

Good advice.

And also understand that it's possible they can't pay. That's not an excuse, and doesn't mean you shouldn't pursue restitution. But the reality is: shit happens.

In my case, I always work with 100% payment upfront, eliminates the problem completely.
Look into invoice factoring services. You sell your invoices to them and get paid upfront. They get a % of your invoice and/or a small processing fee.

Ideally you want a non-recourse factoring agreement (the one where the factoring company takes most of the risk of non-payment), but it might be difficult to get. It helps if you can show that your previous clients paid on time. But then again the freelancing platforms handled that for you.

In any case, it's worth asking around. Have your lawyer review the factoring terms before you agree to anything.

Amen!

Fortunately I only had this problem once, and for me, the way to resolve it was first, with the client. Nagging, explaining to them that if they do not pay, I will sell their invoice to a invoice collection agency, that, if they choose not to pay will affect their credit rating and reputation blah, blah.

The trick is to do this in a serious way, but not overly confrontational and to be clear that all it takes for them is to pay the invoice.

After 6 months of this dance, I said, enough is enough, and initiated the procedure of finding an agency, and then, lo and behold, they paid.

In retrospect I should not have waited 6 months, but your learn with experience. =)

As a palette cleanser and loin girder: https://www.youtube.com/watch?v=jVkLVRt6c1U (You already guessed it was Mike Monteiro.)

For this project:

Did they refuse to pay actively ("We won't pay you."), or passively (No replies to emails.) The latter might be incompetence.

As others mentioned, specific legal advice depends on respective jurisdictions, but an offical lawyer's letter sometimes wakes up legal when accounting is drifting.

Did you deliver the final access to the code / server / credentials? If not, gently bring servers, DBs, platforms to a halt pending final payments.

Future projects:

Contract, always.

Up-front commencement payments, always.

Price yourself higher in the initial quote, and ask for staged payments, such that by the time your delivery schedule is 50-75% done you are 100% paid.

You control the source code accounts, you control the server credentials, you control the database access credentials, you hand over final access after the final check has cleared.

Absolutely.

FU Pay me.

A polite email to the Finance director, or CEO ought to do the trick, and wait a week or two, warning them about the consequences of non-payment and interest on the debt.

Then after the time limit has passed pop down to your local court house to file a small claim or a winding up order if your client is local. You could also sell the debt to a third party. Then it's their problem.

> warning them about the consequences of non-payment and interest on the debt.

You cannot simply add in these penalties though, not suggesting you are implying that.

However any such clauses / penalties need to be clearly laid out in the initial contract, and the contract also needs to be legally enforceable. Always check with the relevant jurisdiction what acceptable penalties are, and get a lawyer.

It depends where you are. In the UK you can add interest to outstanding debt.
It's a good video, but I think some people may miss the point.

You SHOULD be working with a good lawyer ahead of time. You should NOT be regularly suing your clients. Actually suing is expensive, time-consuming, and painful.

You should have a solid, enforceable contract set up ahead of time that you require new clients to sign, and get your lawyer involved if they want to change anything. The contract should ensure that you are within your rights to stop work and take away things they want if they aren't paying on time. If you do it right, you have a smooth and easy escalation path for non-payment, they're the ones who find themselves in a bad situation and have the option of either trying to sue you or just pay you the originally-agreed-upon amount.

I'm not a lawyer or your lawyer and don't even know what jurisdiction anyone is in, so don't do anything without consulting one. But the idea is something like, you only transfer control of servers and services to the customer upon being paid in full, no exceptions, and if they are behind on payment by some particular time and amount, you are explicitly within your rights to shut down services or block their access until such time as their account is paid up.

It's interesting how a good contract is kind of like a good program. The happy case is only like 20% of the work, the other 80% of the code or contract is all about detailing every possible way the happy case could go wrong and exactly what happens when each particular way of going wrong happens.

> Price yourself higher in the initial quote, and ask for staged payments, such that by the time your delivery schedule is 50-75% done you are 100% paid.

Related to this, another technique I've seen used:

* Figure out whatever price you want to quote

* Add 25% to that.

* In the formal quote, show the 125% price and a 20% discount for timely payment of your invoices (however you define that in the contract, maybe 30 or 90 days).

* The final bottom line price is the original price from the first bullet point.

When the client "forgets" to pay, you draw their attention to the terms of the discount and that, without the discount, they will owe 25% more.

Every attorney adds the maximum-legally-accruable interest rate to every invoice they issue and retainer agreement they execute. You should too.
I faced this once in 25 years. I sued, won, and then the company declared bankruptcy.

I guess it depends on how big the client is— bigger clients are easier to pin down… and it also depends on how much they owe you (in my case, it was $25,000)… but my general suggestion is: walk away. Warn your community not to work with them. Be smarter next time.

Smarter how? Well, you could have withheld the final product until you got paid. This is really the only leverage an independent has.

> Warn your community not to work with them

Awful advice. If you walk away with no legal evidence about their wrongdoing and bad mouth them you might get (legitimately!) sued for defamation.

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You underestimate arrogant cheap CEOs.

If there’s somebody who doesn’t know what they’re talking about that’s most likely you.

Really? How old are you, then? How long have you run your own business? This year is my 41st as a professional in this field, and my 25th running my own business. I've written two books.

I'm not a lawyer, but I have been involved in 10 court cases as an expert witness, so I am aware of what it means to launch and win a lawsuit.

How many times have you been sued for defamation? Are you speaking from experience?

> This year is my 41st as a professional in this field, and my 25th running my own business. I've written two books.

you sound like an arrogant ceo

Technically, I am a CEO, yes. I accept that I do sound arrogant to you, since ANYONE sounds arrogant if he is confident in his hard-earned knowledge of how to run a business and is being heard by... who? some random kid on the internet who lacks the self-awareness to realize that he arrogantly and ignorantly dismissed someone else's experience without having any particular relevant experience of his own.
Oh you just revived sweet memories of my times as a freelancer.

As a freelancer, it's sometimes hard to get around the simple idea that you are your own company and that you must act like one: protect and defend your work at all cost. It took me months of time wasted, and thousands of dollars of work stolen to accept the fact I need to change my behaviour, as a freelancer you have roughly two approaches:

- set boundaries early on, don't start any work with a predefined and agreed upon down payment, if the work is more than a few days long: set milestones as need be with payments required.

- lawyer up, be flexible with clients (delays in payments are a common occurrence with any company) but don't be afraid to go after dishonest clients, if you can't afford it or don't feel like going this path then you need to set up as many contingencies as possible upfront (see previous point).

A classic video that might help you get in the right mindset: https://youtu.be/jVkLVRt6c1U

Yes, I have handled a situation like that once, in which the client refused to pay and cut off all communication. It was a remote cross-border gig, and there was no way I could afford a lawyer in the client's country.

After struggling with the problem for a few weeks, I located a debt-collection company, and decided to offer the debt to them, and all related documentation, so they could collect it for themselves. I then informed the client of my intentions via email. I said: I'm never going to see this money, but neither are you.

They got back to me within a couple of hours, and paid before the end of the week.

So annoying that it had to get to that. I hate people who do this, scum of the earth.

Glad you got your money back

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Umm, which part of the world and are they legally grey or white?
Honestly, that's the way to do it. Let them know that you'll sell the debt to someone that is able to screw up their credit.
You either need to get better in selecting clients with money or in proving your value in the relationship so that client wants to keep using you and not burn bridges.

Back to your money: You likely lost it. If they have assets you can threaten them with legal means but I'm experience it never worked.

Going to the legal system without a lawyer just made me waste 500£ and I didn't recoup anything. It would have been money better spent if I paid a hacker to steal his crypto

I had some kind of opposite situation once, a client decided to implement a non scalable shortcut instead of solving the issue in the proper way - then called me after 2 years asking me to fix it or to pay him back his money (something like 2k£). He threatened legal action, I knew the court case would cost him more than that and I just explained the unfairness of the situation and then ignored him.

Others have addressed the process to get paid (legal, factoring, collections etc). And tinco's comment (currently top) on disengaging emotionally is essential reading. I thought it might be useful to describe what some classes of non or late payer look like from the inside:

1) We're solvent, and promised you two week terms - but our accounting dept doesn't work like that.

In this case, whoever signed the contract should have flagged that they can't execute two-week terms. But sometimes their eyes have glazed over before they get to that bit of the contract - or they don't know how their accounting dept works (often with a monthly payment run). In this case, the contractor is likely to eventually be paid. But getting paid on the actual terms would only happen if you have enough leverage to get an executive to force the accounting dept to make an exception, and do it every single time.

2) We're solvent but have a cash flow problem.

Here, a company will push back payments until its cash flow problem is resolved. But that could be months, or even longer. They will make the most critical payments each months - for things that they rely on going forward, like their cloud provider, DNS etc. At this point the engineering team will learn (if they didn't already) to make sure they get notifications of non-payment for critical services, rather than relying on accounting to be able to triage them. Your payment depends on having some kind of leverage - providing a critical service is best, but being the squeaky wheel can also work, as there may be some cash left after the critical ones. Being paid consistently, but always late, is another sign - this means the accounting dept has a hole, but it's of fixed size and they've 'solved' it by taking a float from all their creditors. In this case, you are likely to be paid - eventually.

3) We are about to go bust. This looks rather like 2, except that you won't get consistently paid even late, and their other contractors are also likely to not be being paid. If the company is gambling for resurrection, they may even be more engaging on the actual work side, if they think your work is part of what will save their bacon. Legally, incurring debts if you know that you're insolvent is fraud (at least in the UK). But, that hard to prove and only applies if there isn't some chance of not going bust. I suspect that if there's a big chance of going bust, there's actually a propensity to spend more on contractors - since the chances are that they won't need to pay. Sometimes a company structures itself so that it can make a subsidiary insolvent but keep going. This might be identifiable from filings, but I'm not an accountant so I can't advise how. Although, I'm not going to work again for a company where the CEO has made himself a creditor secured against the company IP....

Others that I don't have any insight into, perhaps others can comment:

4) We are a big company and can get away with X month terms regardless of the contract

5) Shenanigans are our way of doing business. We think of it as "playing hardball".

You say “final invoice”. So I’m guessing you were paid something. You might have gotten paid all you’re going to get.

Let me explain. I don’t know much experience you have with how your customers valuing your work product. Under some circumstances you may have maxed out the value of your work. If you want to keep working with them, or within the community that you share with them, again, you may want to let it go. There’s a lot of moralistic reasons why you may have reached some kind of limit. And from personal experience I know it’s next to impossible to appreciate them at this moment.

But if they were impossible, and you overdelivered, solved the problem with grace and generosity—and still believe you are owed your final invoice…nothing short of legal intervention will jump start a non-paying client.

That said, I saw this little nothing viddy on instagram. It’s a funny FU

https://www.instagram.com/reel/C8meIe6OQpr/

If you're working on an hourly basis, you can ask the client to sign a retainer agreement and have them make an up front payment into an escrow account that you draw from as you complete work hours. It's less complicated to implement than it sounds. When the account gets low, warn the client and ask them to make another retainer payment, and if the account gets to zero, cease working on the project until the retainer account is topped up again.
It all depends on the country you live in and if you have a legal contract. In UK for example you can use a debt collection agency. Those guys will probably give you 50% of the amount and then it's their problem.