$0 New York Small Claims Collection Checklist

How to Calculate Judgment Interest in New York (CPLR 5004)

The Statutory Rate Under CPLR 5004

New York sets post-judgment interest at 9% per annum simple interest under CPLR 5004. Interest begins accruing automatically on the date the court clerk enters the judgment — not the trial date, not the date you receive the notice in the mail. It continues accruing until every dollar of principal, fees, and accumulated interest is paid.

There is one major exception. The Fair Consumer Judgment Interest Act reduced the rate to 2% per annum for consumer debt judgments — actions arising from personal, family, or household transactions such as medical debt or retail credit accounts. Most small claims disputes (security deposit returns, contractor damage, property disputes, breach of contract between individuals) still accrue at the full 9% rate.

If you are unsure which rate applies, look at the underlying claim. A landlord-tenant security deposit case, a property damage suit, or a dispute over services rendered is a standard civil judgment at 9%. A defaulted personal credit card balance or unpaid medical bill falls under the 2% consumer debt rate.

The Calculation Formula

New York uses simple interest, not compound. The annual interest on any balance is:

Annual interest = Unpaid principal × Rate (0.09 or 0.02)

For daily interest (useful when calculating to a specific payment or enforcement date):

Daily interest = (Unpaid principal × Rate) ÷ 365

Here is a concrete example. A New York City small claims court enters a $5,000 breach-of-contract judgment on January 15, 2025. No payments arrive. On January 15, 2026 — exactly one year later — the total owed is:

  • Principal: $5,000.00
  • One year of interest at 9%: $450.00
  • Total balance: $5,450.00

If the debtor makes a partial payment on that date, allocation follows a specific order: the payment is applied first to accrued interest, then to principal. A $600 payment would cover $450 in interest and reduce the principal by $150, leaving a $4,850 balance that continues accruing at 9%.

Tracking Partial Payments Over Time

Multi-year collection efforts with irregular partial payments create balance complexity. Each time you receive money, recalculate:

  1. Count the days since the last payment (or since judgment entry, if this is the first payment).
  2. Calculate accrued interest on the current principal balance for that period.
  3. Apply the payment to interest first, then principal.
  4. Record the new principal balance — this is the base for the next interest calculation.

A worked example with two payments:

  • Judgment entered March 1, 2024: $6,000.00 principal
  • March 1, 2025 — debtor pays $2,000:
    • Year 1 interest: $6,000 × 0.09 = $540.00
    • Payment covers $540 interest + $1,460 principal
    • Remaining principal: $4,540.00
  • March 1, 2026 — creditor enforces:
    • Year 2 interest: $4,540 × 0.09 = $408.60
    • Total balance due: $4,948.60

Keep a written log of every payment, the date received, and the running balance. Enforcement officers and courts expect documented figures when you submit an execution.

Free Download

Get the New York Small Claims Collection Checklist

Everything in this article as a printable checklist — plus action plans and reference guides you can start using today.

Adding Recoverable Costs

Post-judgment interest is only one component of what the debtor owes. You can also recover certain enforcement costs that were advanced out of pocket:

  • Transcript of Judgment fee: $15
  • County Clerk docketing fee: $25
  • Enforcement officer advance deposits and mileage
  • Certified mail costs for information subpoenas

These costs are added to the judgment balance. Interest does not accrue on the added costs unless a court orders otherwise — it runs only on the original judgment principal.

When Interest Stops

Interest stops accruing when the debtor pays the judgment in full — meaning the original principal, all accrued interest, and recoverable enforcement costs. At that point, CPLR 5020 requires you to file a Satisfaction of Judgment within 20 days of full payment. The statutory penalty for failing to file is $100 for a judgment under $5,000 and $500 for a judgment of $5,000 or more, plus any actual damages caused by the delay. A written demand by certified mail, return receipt requested, is an added condition only when a city with more than one million residents is the judgment creditor.

A New York judgment remains enforceable for 20 years under CPLR 211(b), so interest can accumulate for a long time. On a $5,000 judgment at 9%, that is $450 per year — $9,000 in interest alone over the full 20-year lifespan, potentially tripling the original award.

Next Steps

Our New York Judgment Collection Guide includes a printable Judgment Balance and Interest Tracker worksheet designed for exactly this calculation — log each payment, track daily interest, and arrive at an accurate balance whenever you need to submit an execution or negotiate a settlement. It also covers when to use the 2% consumer debt rate versus the standard 9%, and how to present your interest figures to enforcement officers.

Related reading:

Get Your Free New York Small Claims Collection Checklist

Download the New York Small Claims Collection Checklist — a printable guide with checklists, scripts, and action plans you can start using today.

Learn More →