Problems & Special Situations

Unemployment Overpayment Waivers: How They Work

If you've been told you owe money back on unemployment benefits, a waiver is one way to potentially avoid repaying it — but it's not automatic, it's not available everywhere, and it's not the same thing as appealing the overpayment itself. Understanding the difference, and what your state actually offers, matters before you decide what to file.

Updated September 2026

Quick Answer

A waiver forgives repayment of a non-fault overpayment, usually if you can show financial hardship — it never applies to fraud. Most states use some version of a "without fault, and against equity and good conscience" test. But coverage is uneven: a few states, including Texas, offer no waiver at all for regular unemployment overpayments, and several others only built a waiver process for the old federal pandemic programs.

A waiver is not the same as an appeal

An appeal disputes whether the overpayment determination itself is correct — that you were actually ineligible for the benefits in question. Win the appeal, and the overpayment (and any penalty) disappears entirely, whether it was classified as fault or fraud.

A waiver concedes the determination is correct — you did receive benefits you weren't entitled to — and instead asks the state to forgive the debt because you weren't at fault and repaying it would be unfair or a genuine hardship. A waiver is never available for a fraud-based overpayment. Because a successful appeal makes the waiver question moot, some states require your appeal window to close before they'll consider a waiver request; others let you pursue both around the same time.

The two-part test most states use

Where a waiver is available for non-fraud overpayments, most states apply some version of the same two-part federal-derived test: you must show you were "without fault" in causing the overpayment, and that requiring repayment would be "against equity and good conscience" — commonly demonstrated through financial hardship, such as being unable to cover basic living expenses. Federal law doesn't require states to offer a waiver for regular state unemployment overpayments at all; where a waiver exists, states are expected to decide each request individually rather than issue blanket waivers.

Some states don't offer this the way you'd expect

This is the part worth reading carefully before you assume your state works like the ones described above. Texas has no waiver mechanism for regular state unemployment overpayments at all — its published guidance states there's no hardship exception. New York, Florida, and Pennsylvania each built a waiver process, but only for the old federal pandemic-era programs (PUA, PEUC, FPUC, MEUC) — not for regular state benefit overpayments, which in Florida and New York can only be appealed, and in Pennsylvania are instead capped at a maximum recoupment rate rather than waived.

Ohio's standing waiver basis is narrower than the typical hardship test — limited to agency or employer error, not general financial hardship — after a broader pandemic-era waiver program ended. Virginia is a newer addition to this list: it had no waiver provision at all until state legislation created one in 2021.

Overpayment waiver rules by state

California

Waiver available?
Yes (non-fraud only)
Eligibility test
Income-based hardship test against the state's Family Income Level Table
How to apply
Return the waiver application mailed with your overpayment notice; appeal deadline is 30 days

Texas

Waiver available?
No, for regular UI
Eligibility test
N/A — no hardship exception for regular unemployment overpayments
How to apply
No waiver process; a narrow waiver applies only to federal Extended Unemployment Compensation overpayments

New York

Waiver available?
Limited — federal programs only
Eligibility test
Without fault + against equity and good conscience, but only for PUA/PEUC/FPUC/MEUC overpayments
How to apply
Requested through the state, by phone, or by mail; approval link expires in 30 days

Florida

Waiver available?
Limited — federal programs only
Eligibility test
Without fault + equity and good conscience, but the waiver form only covers PUA/PEUC/FPUC/MEUC/LWA
How to apply
Regular Reemployment Assistance overpayments can only be appealed, not waived

Pennsylvania

Waiver available?
Limited — federal programs only
Eligibility test
Not-at-fault, non-fraud, plus proof of hardship — restricted to DUA/FPUC/LWA/MEUC/PEUC/PUA/TRA
How to apply
Regular state overpayments are capped at 1/3 of your weekly benefit instead of waived

Illinois

Waiver available?
Yes (non-fraud only)
Eligibility test
Financial hardship, or you gave up a valuable right relying on the payment, or recovery would be unconscionable
How to apply
Waiver correspondence is agency-initiated — keep your mailing address current

Ohio

Waiver available?
Narrow
Eligibility test
Agency or employer error only, not general hardship; a broader pandemic-era waiver program has ended
How to apply
Current recourse for a disputed overpayment is to appeal, not to request a general waiver

Georgia

Waiver available?
Yes (non-fraud only)
Eligibility test
Not at fault, and contrary to equity and good conscience
How to apply
Submit the waiver application form by email or mail

North Carolina

Waiver available?
Yes ("for good cause")
Eligibility test
Good cause, evaluated only after your appeal rights on the overpayment have expired
How to apply
Apply online or by fax, after the appeal window closes

Michigan

Waiver available?
Yes
Eligibility test
Extraordinary financial hardship
How to apply
Submit the waiver form through your online account or by mail

New Jersey

Waiver available?
Yes, but narrow
Eligibility test
Permanent disability, or repayment "patently contrary to the principles of equity" — a stricter standard than typical hardship
How to apply
Written request to the Division of Unemployment Insurance

Washington

Waiver available?
Yes, by statute
Eligibility test
Not fraud, misrepresentation, or claimant fault, and recovery would be against equity and good conscience
How to apply
No separate public application — hardship cases go through the Collections Unit

Massachusetts

Waiver available?
Yes (non-fraud/non-fault only)
Eligibility test
Financial hardship — inability to cover ordinary expenses, or you gave up other benefits relying on the payment
How to apply
Request online through your unemployment account, or by mail

Virginia

Waiver available?
Yes (added in 2021)
Eligibility test
Without fault + contrary to equity and good conscience (loss of income for shelter, food, medicine, or childcare)
How to apply
The state proactively mails a waiver application with your overpayment notice

Arizona

Waiver available?
Yes, for one category only
Eligibility test
Only overpayments classified "Administrative" qualify — not those classified Fraud or Non-fraud
How to apply
Request through the online claimant portal

State UI agencies are the source of truth for current program details — this table is meant as a starting point, not a substitute for checking with your state's agency.

Frequently Asked Questions

What's the difference between an overpayment waiver and an appeal?

An appeal argues the overpayment determination itself is wrong — that you were actually eligible for the benefits. A waiver accepts that the overpayment is correct but asks the state to forgive repayment because you weren't at fault and paying it back would be a genuine hardship.

Can a fraud overpayment be waived?

No. Waivers are only available for non-fraud, non-fault overpayments — cases involving fraud typically come with mandatory penalties and repayment, on top of possibly losing eligibility for future benefits.

What if my state doesn't offer a waiver for regular unemployment benefits?

A few states, including Texas, have no waiver process for ordinary state unemployment overpayments, and some others only built one for the temporary federal pandemic programs. In those cases, your options are usually to appeal the underlying determination or to request a repayment plan.

Independent guide, not legal or tax advice. View source