New York Liquor Authority C.O.D. List: What It Means and How to Respond

The New York State Liquor Authority’s C.O.D. list identifies retailers reported delinquent on covered alcohol purchases. C.O.D. means cash on delivery. While the restriction applies, the business generally cannot obtain alcoholic beverages on supplier credit, including from a different wholesaler. The listing itself does not automatically suspend the liquor license or require the business to stop serving customers. It changes how the business may purchase inventory; violating that restriction can create a separate disciplinary problem. [1] [2] [3]

Respond promptly: identify each reported invoice, reconcile payments and credits, arrange lawful payment or present a documented dispute, and verify removal or written SLA clearance before resuming credit purchases. A promise to pay, a supplier’s verbal reassurance, or a bank screen showing a scheduled transfer is not the same as confirmed clearance.

In this article Effect of listing · Deadlines · Payment methods · Notices · Disputes · Removal

What does being on the C.O.D. list change?

The credit restrictions arise under ABC Law §§ 101-aa and 101-aaa and the SLA’s delinquent-list regulations in 9 NYCRR Part 68. They apply to covered transactions between licensed manufacturers or wholesalers and retailers. The rules are not simply private collection terms that a salesperson may waive. [2] [3] [4]

Under 9 NYCRR § 68.6, a reported retailer may not purchase or accept alcohol deliveries except for cash until its name is removed or it receives a written SLA release. Manufacturers and wholesalers likewise may not make noncash sales or deliveries to a listed retailer without the required release. An existing unpaid invoice from Supplier A can therefore affect a proposed credit delivery from Supplier B. [4]

The business can generally continue selling lawfully acquired inventory under its otherwise valid license and conditions. Keep that question separate from any suspension, expiration, or other independent restriction on the license. C.O.D. status does not excuse buying through another restaurant’s account, concealing the actual purchaser, or obtaining stock from an unauthorized source.

Which payment deadline applies to the invoice?

Start with the actual delivery date, the beverage, and the supplier’s license. Do not apply one accounts-payable setting to every purchase. The SLA publishes separate annual credit calendars, and its guidance states that manufacturers and wholesalers may offer authorized credit but do not have to offer it. The parties cannot substitute their own extended credit terms for the statutory rules. [5]

Transaction	General payment framework	What to check
Wine or liquor governed by § 101-aa	The credit period runs from delivery through 30 days afterward.	The individual invoice, delivery date, and applicable final-payment date.
Beer and other transactions governed by § 101-aaa	Deliveries fall into recurring credit periods with a common final-payment date.	The relevant delivery-period row, rather than 30 days from each delivery.
Certain cider, mead, or wine-product transactions	The applicable section can depend on the seller’s license.	Section 101-aaa(2) routes specified sales by listed wholesalers and manufacturers to § 101-aa.

The third distinction matters: a beverage’s marketing name alone does not determine its credit calendar. Section 101-aaa(2) identifies sales of wine products, mead, or cider by specified wholesalers, licensed manufacturers of liquor, mead, or wine, and cider producers that instead follow § 101-aa. [2] [3]

Payment dates and reporting dates are different

The final payment date is the retailer’s deadline. The notification date concerns the supplier’s report to the SLA. The beer calendar also identifies a separate delinquent-notice date. A later reporting date should not be used as the business’s ordinary payment deadline. [6] [7]

Two examples from the 2026 calendars illustrate the distinction:

For a wine or liquor delivery on September 1, 2026, the calendar lists October 1 as the retailer’s final payment date and October 6 as the supplier’s notification date.
For beer-calendar deliveries from July 6 through July 19, 2026, the final payment date is July 31, the delinquent-notice date is August 5, and the notification date is August 6.

These are examples for those specific delivery dates, not recurring deadlines. Use the calendar for the actual year and transaction. Preserve the delivery record so the invoice can be placed in the correct period. [6] [7]

A mailed payment has a specific rule

Under 9 NYCRR § 68.5, a mailed remittance must be mailed on or before the final payment date. If it arrives later, the retailer is not deemed in default when the envelope is postmarked no later than the next business day. The wholesaler must retain that envelope for one year. Keep mailing evidence and request preservation of the envelope if timing is disputed. This rule does not make an undated statement that “the check is in the mail” sufficient proof. [8]

What counts as cash, and can a business card be used?

Cash is broader than paper currency. The statutes include qualifying certified checks, money orders, electronic funds transfers, bank officer’s checks or drafts, and checks drawn on the retail licensee’s account, subject to the stated conditions. A check used as cash payment for a delivery must be dated no later than the delivery date and honored when presented. A supplier need not accept an uncertified check from a retailer on the delinquent list. [2] [3]

Separate ordinary purchasing options from purchasing while in default. Section 101-aaa contains an express business-payment-card option for transactions governed by that section. It has requirements for the cardholder’s identity and address, supplier acceptance, invoice disclosures, and the statutory card invoice amount. Supplier participation is optional; the statute defines the card invoice amount as the cash invoice amount plus three percent. [3]

That option does not erase the cash-only restriction on a retailer in default. Section 101-aaa(3) and 9 NYCRR § 68.6 require cash during the applicable restriction. Do not assume that charging a beer order to a business credit card bypasses C.O.D. status. [3] [4]

Ordinary wine and liquor purchases governed by § 101-aa do not have the same business-card authorization. As of the sources-checked date, S9979, a 2026 bill proposing to expand that option, had passed the Senate but remained in Assembly committee. A pending bill is not operating authority. [2] [9]
How do notice and online reporting work?

How do notice and online reporting work?

The statutes describe written default notices. Current regulations also provide for electronic reporting and an optional email-notification procedure. Under § 68.7(a), the supplier reports the retailer’s name and serial number, unpaid invoice delivery date, and amount owed through the Online Delinquent Management System. That electronic posting substitutes for the identified first-class-mail default-notice requirement. Do not assume a listing is ineffective merely because no paper letter arrived. [10]

For a retailer that has opted into a supplier’s email procedure, § 68.4 requires a first notice on or before the final payment date identifying unpaid invoices, the notification date, and the consequence of nonpayment. If the covered balance remains unpaid, the supplier reports on the notification date and sends the required email copy. Keep the supplier’s billing contact current and monitor the designated inbox, including filtered messages. [11]

The statutes impose restrictions following receipt of a default notice; § 68.6 expressly addresses restrictions after online reporting. Do not rely on a perceived gap between a notice, a website update, and the next delivery to continue buying on credit. Resolve the status and use permitted cash terms while the restriction applies. [2] [3] [4]

What should you check immediately after discovering a listing?

Use the SLA’s Are you on the C.O.D. List? page and its Check Delinquent Status link. Follow the current access instructions for the licensed business. The SLA-linked service currently leads to a login page; a general license-status search is not a substitute for checking delinquency status. [1]

Create a record for each reported item:

Licensed entity, premises, and license or serial number.
Reporting supplier and the person handling the account.
Invoice number, delivery date, amount reported, and applicable payment deadline.
Payments, cleared checks, transfer confirmations, and how the supplier applied them.
Issued credits, documented shortages or returns, and remaining disputed amounts.
Default notices, emails, and a dated copy of the status shown online.

Check for another supplier’s report before assuming one payment solves the entire problem. The SLA’s credit-reporting tutorial describes individual delinquency records and explains that removal of one record can leave a retailer listed by the same supplier, another supplier, or both. [12]

How should a disputed invoice or incorrect listing be handled?

Raise the specific error promptly and in writing. Identify whether the dispute concerns payment already made, the amount due, or the quantity sold or delivered. Attach the relevant evidence and request a corrected account and delinquency entry where appropriate. A general objection that a bill “does not look right” gives the supplier little to investigate.

For wine and liquor accounts, § 101-aa(3) expressly prevents default where an issued account credit, after application to all debts owed by the retailer, is sufficient to cover the alleged default. An expected return credit or disputed oral promise is different from an issued credit that satisfies that rule. Obtain the actual credit memo and account reconciliation. [2]

A limited dispute procedure is not an automatic grace period

SLA Advisory 2011-1 addresses wine-and-spirits suppliers and retailers using its optional email procedure. It describes a reporting delay of no more than seven calendar days when the retailer raises the specified dispute before the notification date, the wholesaler believes it may be valid, and the retailer has paid all undisputed portions of each invoice. The wholesaler investigates and makes any warranted adjustment; an unresolved unpaid amount can still be reported. This is not an automatic extra week whenever a retailer objects. [13]

Read that advisory with the current online-reporting regulations. Ask for written confirmation that the conditional dispute procedure is being applied, and continue monitoring the account. A dispute does not independently authorize credit purchases after a default restriction has attached. [4] [10] [13]

Ask the SLA to determine disputed delinquency status

Sections 101-aa(4) and 101-aaa(4) authorize the SLA to receive the parties’ statements and decide whether the retailer should appear on the list when a covered dispute cannot be adjusted between them. Submit a concise chronology, the reported entries, supporting records, the supplier’s response, and the correction or relief requested. [2] [3]

The SLA directs C.O.D. matters to its Wholesale Bureau, currently at Wholesale.Bureau@sla.ny.gov. Its Contact Us page provides the current contact route. Advisory 2011-1 describes a maximum five-business-day period for documentary submissions after the agency elects to review a dispute and notifies the parties. Follow the actual agency notice promptly; sending an initial complaint does not itself guarantee review, removal, or permission to buy on credit. [14] [13]

When must the supplier remove a paid delinquency?

Under § 68.7(c), after receiving full payment of the entire amount due and payable on the reported invoice for alcohol and associated delivery charges, the manufacturer or wholesaler must remove the paid delinquency through the online system. The rule distinguishes payment methods: [10]

Payment method addressed by the rule	Removal timing
Cash, certified check, bank officer’s check, draft, or money order	The supplier must act during the same business day it receives payment.
Ordinary check	Removal is deferred until the check clears the bank.

Before paying, confirm the precise invoice balance and allocation of funds. If using electronic funds transfer, preserve proof of completed receipt and request confirmation of the supplier’s removal action; initiating a transfer does not establish that the supplier has received cleared funds. The rule’s express ordinary-check distinction should not be replaced with a promise of instant removal for every payment method. [10]

Request written confirmation identifying the entries removed, then recheck the business’s actual status. A partial payment does not satisfy the full-payment removal rule. Paying the oldest invoice also does not eliminate another unpaid invoice or another supplier’s entry. If a paid entry remains, send the supplier the payment evidence and escalate the documented failure to the Wholesale Bureau. [10] [12] [14]

Can the SLA authorize credit before ordinary clearance?

The statutes allow the SLA to permit otherwise lawful credit sales after actual payment or on good cause shown. Section 68.12 also authorizes a release after investigation and a showing of good cause. This is discretionary relief, not a release a retailer can create for itself. Obtain the agency’s written authorization and provide it to suppliers as required by § 68.6. Removal or release does not compel a supplier to resume extending credit. [2] [3] [4] [15]

What if the supplier never reported the debt?

A reporting problem does not automatically cancel a civil debt. In Eber Bros. Wine & Liquor Corp. v Rare Spirits, Inc., 21 Misc. 3d 201, 207–208 (Sup. Ct., Monroe County Aug. 1, 2008), the court rejected the proposition that § 101-aa prohibited a wholesaler from collecting an unreported delinquency. The court denied competing summary-judgment requests because other factual and contract issues required further development; it did not decide that every claimed balance was collectible or extinguished. [16]

The practical distinction is between regulatory delinquency status and the underlying payment claim. Sections 101-aa(8) and 101-aaa(7) preserve suppliers’ ability to seek payment through legal action. Contest an incorrect listing with evidence, while separately addressing any demand or lawsuit and its response deadline. [2] [3]

Can C.O.D. status affect discipline, renewal, or a business sale?

Improper credit purchasing can lead to license discipline. The statutes provide possible suspensions for purchases or deliveries on unauthorized terms. A dishonored instrument tendered as cash by a listed retailer carries additional potential suspension consequences. These are enforcement provisions, not a statement that every listing automatically produces a suspension. [2] [3]

For the wine-and-liquor framework, § 101-aa(7)(a) addresses liquidation of unpaid balances through three equal monthly installments and states that the SLA shall not refuse renewal because of that indebtedness or failure to pay it. That provision does not extend the original invoice deadline, authorize new credit purchases while restricted, or excuse a late or incomplete renewal application. Keep renewal compliance and resolution of supplier debt on separate calendars. [2]

A business purchase also requires attention. Under § 68.11, unless the SLA provides otherwise, a purchaser issued a license who assumes the debts of a seller on the delinquent list becomes subject to cash purchasing and listing. The rule concerns the specified debt-assumption situation; it does not say every buyer at the same address automatically inherits a former operator’s delinquency. Review the purchase agreement, assumed liabilities, supplier accounts, and clearance before closing. [17]

How can an owner prevent repeat defaults?

Record the delivery date when receiving each order, not only when the invoice reaches the bookkeeper.
Assign the correct credit calendar and schedule payment ahead of the final-payment date.
Reconcile shortages, returns, and issued credits before the account becomes overdue.
Monitor supplier notices and maintain a backup person who can act when the owner is unavailable.
Keep funds available for lawful C.O.D. deliveries if a restriction arises.
Treat confirmed removal or written SLA release as a required step before restoring supplier-credit purchasing.

Rodriguez Law can assist with disputed C.O.D. listings, supplier-record reconciliation, SLA submissions, and the licensing consequences of a business transaction. Prompt, documented action can address the payment issue while keeping inventory purchasing within the applicable rules.

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