Author Archives: James Claymon

DOL Pauses Enforcement of New Independent Contractor Rule — What Employers Need to Know

As of May 1, 2025, The U.S. Department of Labor (DOL) has paused enforcement of its 2024 Independent Contractor Rule, which introduced a more detailed “economic reality” test for determining whether a worker is an employee or an independent contractor under the Fair Labor Standards Act (FLSA). Even though the rule technically remains in effect, DOL investigators have been instructed to stop applying it in active enforcement cases. Instead, the agency is reverting to earlier guidance from 2008 and 2019.

What Was the 2024 Rule?

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On February 18, 2025, the U.S. District Court for the Eastern District of Texas granted a stay order on its previously issued preliminary nationwide injunction pausing the enforcement of the Corporate Transparency Act (CTA). As a result, non-exempt reporting companies are once again subject to beneficial ownership reporting requirements.

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued new guidance in light of the order:

1. For most reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025.

2. Reporting companies formed or registered on or after February 18, 2025, must file within 30 days from the date of creation or registration.

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