A New York dual agent must have:

Verbal consent from only one party is doubly insufficient: New York law requires consent from both parties, and it must be in writing, not merely spoken. A verbal agreement leaves no paper trail and cannot protect the agent or either principal if a dispute arises.

Court approval is not required for dual agency in New York; dual agency is a private contractual arrangement between the agent and the principals, governed by DOS regulations and disclosed agency law, not by judicial oversight. Requiring court approval would make dual agency impractical and is simply not part of New York real estate law.

The Department of State (DOS) does not pre-approve individual dual agency arrangements on a case-by-case basis; rather, the DOS sets the regulatory framework that licensees must follow. Compliance is the agent's responsibility, and enforcement happens after the fact if violations occur — not through advance DOS sign-off on each transaction.