Ariz. Rev. Stat. » Title 23
Arizona Revised Statutes

Ariz. Rev. Stat. § 23-1025 (2026)

Agreement by employee to waive compensation or to pay premium void; unlawful collection of premium; classification

✓ current as of May 2026
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A. An agreement by an employee to waive the employee's rights to compensation, except as provided in this chapter, or an agreement by an employee to pay any portion of the premium paid by the employee's employer is void.

B. It is unlawful for an employer to intentionally collect or receive any premiums from an employee for workers' compensation insurance, except as provided in this chapter. A violation of this subsection is a class 6 felony.  

Notes of Decisions
Cited in 11 cases, 1959–2005 · leading case: Safeway Stores, Inc. v. Indus. Comm'n, 730 P.2d 219 (Ariz. 1986).
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Safeway Stores, Inc. v. Indus. Comm'n, 730 P.2d 219 (Ariz. 1986). · cites it 31× “The court of appeals held that because A.R.S. § 23-1025 1 prohibits settlement once compensability has been established, the Industrial Commission (Commission) lacks jurisdiction to accept or review post-compensability settlements.”
St. Luke's Hosp., cna/Ins. v. Indus. Com'n, 559 P.2d 674 (Ariz. Ct. App. 1976). · cites it 16× “In doing so, he held that the settlement agreement entered into in 1970 was void by reason of A.R.S. § 23-1025. He further treated the Petition to Reopen as a Request for Hearing on the original denial of claimant's 1970 claim.”
Naslund v. Indus. Com'n of Ariz., 110 P.3d 363 (Ariz. Ct. App. 2005). · cites it 3× “Attempted waivers of compensation are void under A.R.S. § 23-1025(A) (Supp.2004), and assignments of compensation are generally prohibited by A.”
Worthington v. Indus. Comm'n of Arizona, 338 P.2d 363 (Ariz. 1959). · cites it 4× “" The answer to the question put depends entirely on whether the claimant's decedent was "killed by accident arising out of and in the course of his employment", A.”
Safeway Stores, Inc. v. Indus. Comm'n, 730 P.2d 214 (Ariz. Ct. App. 1985). · cites it 5× “§ 23-906 provides that an employee is generally deemed to have accepted workers’ compensation unless, prior to sustaining injury, the employee rejects the provisions of the workers’ compensation law by signed and dated written notice delivered to the employer before the injury.”
Gray v. Indus. Comm'n, 539 P.2d 973 (Ariz. Ct. App. 1975). · cites it 2× “§ 23-1025, the Court made these statements : “The provisions of our Workmen’s Compensation Act make it an exclusive remedy for an employé or his dependents to recover compensation from an employer for an injury sustained by the employé in the course of his employment.”
Jones v. Indus. Com'n of Arizona, 562 P.2d 1104 (Ariz. Ct. App. 1977). · cites it 2× “A.R.S. § 23-1025 states: “An agreement by an employee to waive his rights to compensation, except as provided in this chapter .”
Worthington v. Indus. Comm'n, 333 P.2d 277 (Ariz. 1959). · cites it 4× “The law of this state is expressed in the unambiguous language of A.R.S. § 23-1025. "An agreement by an employee to waive his rights to compensation * * * shall be void.”
Travelers Ins. Co. v. Indus. Comm'n, 518 P.2d 1015 (Ariz. Ct. App. 1974). · cites it 2× “This case is important beyond the disputed money since it challenges the basic concept that the Industrial Commission shall control the proceedings under the Arizona Workmen’s Compensation Act.”
Holsum Bakery v. Indus. Comm'n, 955 P.2d 11 (Ariz. Ct. App. 1997). “Safeway cited other policies that apply equally to the settlement of future medical benefits.”
Cunningham v. Indus. Comm'n, 494 P.2d 48 (Ariz. Ct. App. 1972). · cites it 4× “Cunningham contends that the $6,-500 was a settlement and thus void under A.R.S. § 23-1025 (1956) which states: “An agreement by an employee to waive his rights to compensation, except as provided in this chapter, or an agreement by an employee to pay any portion of the premium…”
— Ariz. Rev. Stat. § 23-1025(A) — 2 cases
Naslund v. Indus. Com'n of Ariz., 110 P.3d 363 (Ariz. Ct. App. 2005). “Attempted waivers of compensation are void under A.R.S. § 23-1025(A) (Supp.2004), and assignments of compensation are generally prohibited by A.”
Safeway Stores, Inc. v. Indus. Comm'n, 730 P.2d 219 (Ariz. 1986). “The court of appeals held that because A.R.S. § 23-1025 1 prohibits settlement once compensability has been established, the Industrial Commission (Commission) lacks jurisdiction to accept or review post-compensability settlements.”
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