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DOL clarifies FLSA exemption applicable to retail and service employees

March 2026 employment law letter
Authors: 

Catherine C. Buchanan, Whiteford, Taylor & Preston, L.L.P.

The Department of Labor (DOL) started off 2026 by issuing numerous opinion letters on issues arising under the Fair Labor Standards Act (FLSA). Opinion Letter FLSA2026-4 addresses questions regarding the overtime exemption applicable to retail and service employees.

Defining the retail and service employee exemption

The FLSA requires employers to pay nonexempt employees one and one-half times their regular rate of pay for any hours worked over 40 hours in a workweek. Section 7(i) of the FLSA exempts retail and service employees from the overtime requirement if:

·     Their regular rate of pay exceeds 1.5 times the applicable minimum wage; and

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