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State Laws Complicate Salary Requirements for Exempt Employees

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With the U.S. Department of Labor’s recent increases to the minimum salary or fee amount for certain exempt employees , many employers are reviewing the exemption status of their employees. In doing so, employers should be mindful of varying state law requirements, which may be higher than even the newly increased federal thresholds. Increased salary thresholds for white-collar exemptions under FLSA In April 2024, the DOL issued final regulations raising the white-collar exemption salary threshold under the Fair Labor Standards Act (FLSA). The first increase under this rule went into effect on July 1, 2024, increasing the minimum salary for the executive, administrative, and professional exemptions to $844 per week (approximately $43,888 per year). Another increase is planned for January 1, 2025—further raising the threshold to $1,128 per week (approximately $58,656 per year)—and automatic increases will commence on July 1, 2027, and every three years thereafter. While some court chall...