Commission Clawback Policy Template: Free Word (2026)

Commission clawback policy template: the short answer

A clawback policy sets out when commission lapses because the customer cancels, does not pay or receives a credit note, within which window, how the amount is calculated and how it is offset. In Denmark an employer cannot simply deduct an amount from salary, so the rules must be agreed in writing in advance. Download our free Word template with ready-to-use clause text and guidance.

Download the commission clawback policy template (Word, free)

The template and this article are general guidance, not legal advice. They are written for companies employing salespeople in Denmark. Check your collective agreement and employment contract, and have the rules reviewed if you are in doubt.

The template is an annex to a commission agreement or a commission plan and is written for salaried employees under the Danish Salaried Employees Act (funktionærloven). It has 10 sections with fields in lavender brackets, options and short guidance notes you delete before the policy is signed. It is part of our free commission and sales compensation templates.

What is a commission clawback?

A clawback means that commission that has been calculated or paid lapses in full or in part because the sale does not hold. The original month is not changed. Instead, a deduction appears in the month the customer cancels, and the amount is offset against later commission. The model is described under clawback in our commission models, and typical windows and rules are covered in our guide to commission clawbacks.

What does Danish law say?

There is no single Danish statute on clawbacks or on set-off against salary. The rules come from the Salaried Employees Act, the agreement with the employee and case law. The key points:

The agreement must be in place in advance. The components of pay, including commission, must be stated in writing in the employment contract or an annex (section 3 of the Danish Employment Contracts Act, ansættelsesbevisloven). Whether commission that has already been earned and paid can be claimed back depends mainly on the agreement.
Advances can only be covered by pay. If the rep has received an advance on commission, the employer can only have it covered by pay owed to the rep under section 9(2) of the Salaried Employees Act. It cannot be claimed as an ordinary debt.
Set-off against salary has limits. As a starting point, the employee is entitled to their pay without deductions. Employers' organisations describe the practice like this: the claim must be clear, documented and due and directly connected to the employment, and the employee must be left with a certain subsistence minimum under the rules of the Administration of Justice Act (retsplejeloven). Holiday pay, the holiday allowance and feriegodtgørelse can only be set off against a claim arising from a wrongful act that the employee has admitted or a court has established (section 29 of the Danish Holiday Act, ferieloven), so a clawback cannot be deducted from holiday pay.
Do not wait too long. Delay can cost you the right to set off, even before the claim is time-barred.
Rights under the Salaried Employees Act cannot be waived to the employee's detriment by agreement (section 21).

That is why the safest model is to offset clawbacks against later commission and not demand repayment. For the wider rules on commission pay in Denmark, see commission pay in Denmark in the glossary.

What is in the template?

Section	What it covers	Options in the template
1. Purpose and scope	Who and which sales the policy applies to	One rep or the whole plan
2. When clawback applies	Cancellation, non-payment, credit note, termination and returns	Delete the events you do not use
3. Clawback period	Window from commission, invoice or contract start	For example 3 months, longer for multi-year contracts
4. Calculation	Basis × rate, partial cancellation and cap	Effective rate or tier rate
5. Offset	Offset against later commission and negative balance	At most for example 50% per month, with or without fixed salary
6. Repayment	Whether a remaining amount can be claimed	No repayment or a written instalment plan
7. Leaving the company	Clawback after leaving and negative balance	Offset against final commission or lapse
8. Statement and objections	Statement line, documentation and deadline	Offset before or after a decision
9. Changes	Notice for changes that leave the rep worse off
10. Signatures	Both parties

Worked example

Example: A sale of DKK 200,000 earned commission in March. The rep's effective rate in March was 7%, so the commission was DKK 14,000. In May, the customer cancels half of the agreement, within the 3-month clawback period.

Clawback: 100,000 × 7% = DKK 7,000, shown as a line on the May statement with customer, deal ID and March as the original month.
Offset in May: The rep earns DKK 12,000 in commission in May. The offset is at most 50%, i.e. DKK 6,000. Paid: DKK 6,000. The remaining DKK 1,000 carries forward as a negative balance.
Offset in June: The rep earns DKK 9,000. The DKK 1,000 is offset, and DKK 8,000 is paid.

March does not change. The rep can see what happened and why, and the fixed salary is not touched.

How to choose the rules

Period

A short period, for example 3 to 6 months, lets the rep know what they have earned. For agreements where commission is calculated on a multi-year contract value, a longer period can be reasonable, but then clawback should only cover the part the customer does not pay.

Which events

Make the list exhaustive, and use the same terms as in your CRM and finance system. A late payment should only trigger clawback after a clear deadline, for example 60 days after the due date and debt collection. If the cancellation is caused by something the company is responsible for, such as a failed delivery, there should be no clawback.

Offset, not repayment

The template proposes that clawbacks are only offset against later commission, with a monthly limit, so the rep is not left with a month without commission. If you also choose to offset against fixed salary, it must be in the agreement with a maximum amount and a notice period, and you must stay within the limits on set-off against salary.

Leaving the company

Decide in advance what happens to a negative balance when the rep leaves. The simplest solution is to offset it against the final commission and let the rest lapse. Clawback should also apply to commission on sales that close after the rep has left. See also our guide to commission upon termination.

The clawback rules must fit the rest of the agreement. Use them as an annex to our commission agreement or commission plan, and use the same window in every document.

Common mistakes

Clawback is mentioned in the plan in one word, with no window, calculation or offset rule.
The rules are introduced after the commission has been earned.
The amount is deducted from fixed salary without an agreement.
The original month is edited, so statements already sent no longer match.
Clawbacks are shown without a reference, so the rep cannot recognise the deal.
There is no rule for a negative balance when the rep leaves.

Prowi and clawbacks

Prowi calculates commission continuously from your CRM data and handles adjustments and clawbacks as rules instead of manual edits in a spreadsheet. Deductions appear on the rep's statement, and the statement is approved before the amount is passed on to payroll. Book a demo to see it with your own rules.

FAQ

Can an employer in Denmark claw back commission?

It depends mainly on the agreement. If clawback has been agreed in writing in advance, commission on cancelled sales can be offset against later commission. An advance on commission can only be covered by pay owed to the rep under section 9(2) of the Salaried Employees Act.

Can a clawback be deducted from salary?

Only within the limits on set-off against salary: the claim must be clear, documented and due, directly connected to the employment, and the employee must be left with a subsistence minimum. The safest option is to offset against later commission.

How long should the clawback period be?

There is no statutory period. A short period, for example 3 to 6 months, is easiest for reps to work with. Use the same period in the agreement, the plan and the calculation.

What happens to a clawback when the rep leaves?

It must be in the agreement. The template lets you choose between offset against the final commission, offset against final commission and salary to the extent the law allows, or letting the balance lapse.

Is the commission clawback policy template free?

Yes. You can download the Word file and use it freely. It is a starting point, not legal advice.

Sources

This article is general information, not legal advice. Check your collective agreement and employment contract.