UPDATE – DOL’s New Minimum Salary Requirements for the FLSA’s White-Collar Exemptions Take Effect (For Every Covered Employer Except Texas)
July 3, 2024
Publications
In April, we wrote about the U.S. Department of Labor’s new regulations set to take effect on July 1, 2024. These new regulations significantly increase the minimum salary required for employers to meet the Fair Labor Standards Act’s white-collar overtime exemptions.
A number of legal challenges were filed seeking to block the new regulations from taking effect. Late on Friday, June 28, 2024, a federal court in Texas issued a narrow injunction blocking enforcement of these new requirements, but only against the State of Texas and only in Texas’s capacity as an employer. Although the State of Texas sought a nationwide injunction (similar to what was issued in 2016 in response to significant increases to the minimum salary requirement issued by the Obama Administration’s DOL), the court elected to issue a narrow injunction that covered only the State of Texas as an employer.
This decision has no immediate impact on private employers or employers in Pennsylvania. That means that the new minimum salary requirement of $844 per week for these FLSA overtime exemptions has taken effect for all employers other than the State of Texas, with another significant jump to $1,128 per week set to take effect on January 1, 2025.
Additional legal challenges remain pending, and the ultimate fate of the DOL’s regulations remains unknown. However, for the time being, non-Texas employers must meet the new increased minimum salary requirements to treat employees as exempt from the FLSA’s overtime pay requirements under most of the white-collar exemptions.
