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DOL Restores 2019 Overtime Exemption Rules: Employer Guide

The U.S. Department of Labor issued a technical amendment restoring the 2019 salary thresholds for white-collar overtime exemptions under the Fair Labor Standards Act.

Effective immediately, the amendment updates federal overtime regulations to reflect the standards employers already follow after courts vacated the 2024 rule. It confirms the current federal baseline and removes outdated text from the regulations.

Under the restored rule, most exempt employees must earn at least $684 per week, or $35,568 annually. The highly compensated employee threshold is set at $107,432 a year, with at least $684 per week paid on a salary or fee basis, according to the U.S. Department of Labor. This follows a federal court decision vacating the Department’s 2024 final rule, so the 2019 threshold remains in effect.

After business groups challenged the rule, a federal court in Texas vacated it in November 2024. Since then, the Wage and Hour Division has enforced the 2019 salary levels, which many employers had already returned to.

This amendment aligns the regulations’ text with the legal and enforcement reality employers face today and does not impose new requirements.

Why State Law Still Matters

Federal clarity does not reduce state-level compliance risk. Employers must still follow the law that offers employees greater protection.

The amendment affects federal salary requirements only. It does not change state overtime exemption rules, which may carry higher salary thresholds along with different duties tests.

This matters in states like California and Washington, where exempt salary thresholds can be much higher than the federal minimum. Multi-state employers should always consider location-specific rules in classification reviews.

What Employers Should Do Now

The amendment offers certainty but should not slow compliance efforts. Employers still need a disciplined process to review exempt classifications and monitor legal developments.

the key takeaway is: employers should keep auditing exemptions, documenting classification decisions, training managers on overtime rules, and watching for further federal and state changes.

3 Steps to Stay Compliant

If your organization already uses the 2019 federal thresholds, immediate payroll changes may not be necessary. However, it is a good time to confirm every exempt role meets the full exemption standard.

  • Review salary levels to confirm exempt employees meet the federal minimum and any higher state threshold.
  • Validate the salary basis and duties tests for each exempt role, not just the job title.
  • Document your analysis and schedule periodic reviews as federal and state rules continue to evolve.

The DOL’s amendment closes the book on the invalidated 2024 rule, but the wider message for employers is unchanged: overtime compliance still depends on disciplined classification reviews, strong documentation, and close attention to state law.