https://www.irs.gov/newsroom/coronavirus-related-relief-for-retirement-plans-and-iras-questions-and-...

Specifically, the legislation restricts relief to qualified participants with a valid COVID-19 related reason for early access to retirement funds. These include:

Being diagnosed with COVID-19
Having a spouse or dependent diagnosed with COVID-19
Experiencing a layoff, furlough, reduction in hours, or inability to work due to COVID-19 or lack of childcare because of COVID-19
Have had a job offer rescinded or a job start date delayed due to COVID-19
Experiencing adverse financial consequences due to an individual or the individual’s spouse’s finances being affected due to COVID-19
Closing or reducing hours of a business owned or operated by an individual or their spouse due to COVID-19

Would commissions be included under the "inability to work" if you can't make any sales to earn commission?