Introduction
In a significant move to enhance worker protections, the U.S. Department of Labor (DOL) announced the new overtime rules on April 23, 2024. These new overtime rules aim to expand overtime pay eligibility to millions of salaried workers by increasing the salary thresholds that determine exemption under the Fair Labor Standards Act (FLSA). Although the new overtime rules were set to take effect on July 1, 2024, their implementation has faced legal challenges, resulting in a nationwide vacatur by a federal court in Texas on November 15, 2024.
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Key Changes Under the Final Rule
The DOL’s final rule sought to raise the standard salary level for exemption from overtime pay:
- From $684 per week ($35,568 annually) to $844 per week ($43,888 annually) effective July 1, 2024.
- Further increasing to $1,128 per week ($58,656 annually) on January 1, 2025.
Additionally, the total annual compensation requirement for highly compensated employees (HCEs) was set to increase:
- From $107,432 to $132,964 effective July 1, 2024.
- Further increasing to $151,164 on January 1, 2025.
The rule also included a provision for automatic updates to these thresholds every three years, starting July 1, 2027, to reflect current earnings data.

Impact on Workers
The DOL estimated that approximately 4.3 million workers would benefit from the expanded overtime protections in the first year of implementation. This includes 2.4 million women and 1 million workers of color. The most affected sectors were projected to be professional and business services, health care and social services, and financial activities.
Legal Challenges and Court Ruling
Shortly after the announcement, a coalition of business groups filed lawsuits challenging the rule, arguing that the DOL exceeded its authority by prioritizing salary thresholds over job duties in determining overtime eligibility. On November 15, 2024, U.S. District Judge Sean Jordan vacated the rule nationwide, stating that the DOL’s approach was inconsistent with the FLSA’s emphasis on job duties.
Current Status and Next Steps
Following the court’s decision, the DOL reverted to enforcing the 2019 rule’s thresholds: $684 per week for standard salary level and $107,432 annually for HCEs. The DOL has filed a notice of appeal, and the outcome of ongoing litigation will determine the future of the 2024 final rule.
Conclusion
The DOL’s attempt to modernize overtime protections highlights the ongoing debate over worker compensation and employer obligations. While the rule aimed to extend benefits to millions, legal challenges underscore the complexities of labor law reform. As the appeal process unfolds, employers and employees alike await clarity on the standards governing overtime eligibility.
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Frequently Asked Questions (FAQs)
1. Who qualifies for overtime under the new Department of Labor rule?
Under the new overtime rules finalized in 2024 (now vacated), salaried workers earning less than $43,888 annually as of July 1, 2024, and less than $58,656 annually as of January 1, 2025, would have qualified for overtime pay if they worked more than 40 hours a week. These new overtime rules cover many professionals in administrative, executive, and managerial roles who were previously exempt under older standards.
Source: U.S. Department of Labor
2. Why was the rule blocked by the court?
A federal judge ruled that the Department of Labor overstepped its authority by focusing too heavily on salary thresholds rather than job duties. The judge stated that the rule failed to consider whether workers meet the FLSA’s “duties test” for exempt status.
Source: Reuters
3. How many workers would have benefited from the rule?
The Department of Labor estimated that 4.3 million workers would gain overtime eligibility. These include workers who are currently exempt but fall below the new salary thresholds especially in healthcare, education, retail, and business services sectors.
Source: Economic Policy Institute
4. Is there a possibility the rule will be reinstated?
Yes. The Department of Labor has appealed the court’s decision. If the appeal is successful, the rule may be reinstated or revised. Employers are advised to monitor ongoing legal developments to stay compliant.
Source: U.S. Department of Labor