Every entry below is dated, sourced, and tagged to the issues it affects — the same entries that power the "litigation & rulemaking watch" strips on the issue briefs. Subscribe by Atom feed to get additions as they're published.
State summaries and reading tools clarified after a fresh reader review#
The State Center now aligns its hotel-rate cards, map labels and dated change table with the underlying sources, including published Nebraska wage steps and qualified tipped-wage schedules. The Illinois hotel-safety effective date and New Jersey statutory citation, coverage and limited collective-bargaining exception are corrected. The California guide distinguishes Los Angeles health-benefit contributions from cash payments owed on overtime hours. Search is available throughout the brief library, with redundant heading-only results removed and homepage-section links corrected; navigation labels are consistent; state-guide links preserve the selected state in the tipped-overtime calculator. Clearer scenario labels, tool descriptions, final-pay guidance and methodology explanations improve orientation, and the California hotel-law table has more room on desktop. The existing Gold Standard presentation, detailed content and calculation engines are retained.
Scheduled state and local changes · Hotel-specific laws · State-aware calculator
Tip credit guidance clarified after reader review#
The Tip Credit brief now distinguishes D.C.’s retained credit from Chicago’s phase-out, limits unlawful-pool consequences to the affected workers and periods, and clarifies service-charge wages and recordkeeping. D.C.’s repealed quarterly tipped-wage reporting mandate is identified as historical; the current agency portal accepts voluntary submissions. The Santa Monica worked example now distinguishes the current $25.00 hotel rate from the earlier $22.50 rate. Navigation, source labels, subscription guidance, and the calendar’s upcoming-date shortcut have also been clarified.
Tip Credit brief · Santa Monica example · Subscribe to developments
Legal content, wage rates, and calculator rules reviewed#
Current general adult wage and tipped-cash floors were checked across all 50 states and DC, alongside the issue briefs and key reference rules. Corrections include federal manager eligibility and §7(i), state side-work limits, hotel workload calculations, pay-period penalties, IRS reporting, and statutory exceptions. The familiar page layout is retained. See the methodology for calculation limits and source-review scope.
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Major Seven new audit and planning tools launch on this site#
The tools library grows from three calculators to ten interactive tools: a stacked Workweek Compliance Auditor (federal + state + city + hotel-ordinance layers in one pass), a Housekeeper Workload & Piece-Rate Auditor covering the square-footage ordinances, a Tip Pool & Service Charge Architect with per-person legality verdicts, a Portfolio Rate Forecaster with scheduled steps through 2030 and beyond, a Wage-Hour Exposure & Penalty Modeler, a Fair Workweek Premium Calculator for the five laws that reach hotels, and a Hotel Compliance Profiler.
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Major IRS tipped-occupation final regulations take effect#
TD 10044, published April 13, 2026 and effective June 12, lists bellhops (301), concierges (302), hotel desk clerks (303), and housekeepers (304), along with covered valet and spa occupations. Being listed satisfies one condition for the qualified-tip deduction; taxpayer, income, reporting, and other statutory restrictions still apply. Mandatory service charges are not qualified tips.
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Santa Monica withdraws hotel health-benefit proposal; $25.00 wage match proceeds#
The Santa Monica City Council withdrew proposed amendments that would have added an LA-style hotel health-benefit payment. The hotel worker wage still rises to $25.00 on July 1, 2026 under the ordinance clause matching the Los Angeles hotel rate.
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Chicago's updated Fair Workweek rules take effect#
Recalibrated coverage rules for Chicago's Fair Workweek Ordinance — which covers hotels — took effect June 1; the covered-employee pay ceiling rises to $33.85/hour or $64,945.55/year on July 1, 2026.
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Major Los Angeles delays the "Olympic Wage" endpoint to 2030#
Ordinance 188944 (effective June 29, 2026) keeps the hotel worker minimum wage step to $25.00 on July 1, 2026 but defers the $30.00 endpoint from 2028 to 2030, and resets the hotel health-benefit payment to $4.25/hour from July 1, 2026 ($6.00 from July 2027). Glendale and Santa Monica track the LA rate.
Jackson Lewis — LA amends hotel worker minimum wage ordinance
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Major Chicago freezes the tipped wage at 76% of minimum for two years#
The May 20, 2026 amendment keeps the cash percentage at 76% through June 2028 for employers with 21+ employees, then 84% in July 2028, 92% in July 2029, and 100% in July 2030. Employers with 4–20 employees remain at 76% through June 2030, then reach 84%, 88%, 94%, and 100% each July from 2030 through 2033. Dollar cash floors continue to follow the annually adjusted minimum wage.
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Major DOL formally restores the $684/week salary threshold#
After the Fifth Circuit appeals were dismissed, DOL's technical amendment removing the vacated 2024 overtime rule took effect: the operative thresholds for the white-collar exemptions are again $684/week ($35,568/year) and $107,432 for highly compensated employees.
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DOL proposes replacement independent-contractor rule#
The NPRM (RIN 1235-AA46) would rescind the 2024 independent-contractor rule and adopt a streamlined economic-reality analysis. Comments closed April 28, 2026; a final rule is expected late 2026. WHD already declines to enforce the 2024 rule (FAB 2025-1), but private plaintiffs can still invoke it.
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Federal contractor minimum wage (legacy contracts) set at $13.65#
With EO 14026 rescinded, DOL announced the EO 13658 rate for legacy covered contracts: $13.65/hour ($9.55 tipped) effective May 11, 2026. Newer contracts fall back to SCA prevailing wages and the FLSA floor — relevant to federal-land concessioner lodges.
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DOL opinion letter clarifies the 7(i) commission exemption and tips#
Opinion Letter FLSA2026-4 addresses which minimum wage applies to the §7(i) 1.5×-minimum-wage test and how tips count toward the more-than-half-commissions test — directly relevant to hotel spa and salon compensation plans.
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California preserves enforcement of hotel recall rights through 2026 (AB 858)#
AB 858 preserves Labor Commissioner enforcement of Labor Code §2810.8 violations occurring on or before December 31, 2026 after the statute becomes inoperative on January 1, 2027. The operating period had already been extended by prior legislation. The section includes its express collective-bargaining waiver provision.
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DOL opinion letter: guest contact drives tipped-employee status#
FLSA-2025-03 applies the tipped-occupation test to an oyster shucker and kitchen-backroom bartender on the stated facts. Guest interaction is relevant to that analysis, but the letter does not turn every guest-contact employee into a tipped employee or exclude every worker without direct contact. Apply the actual occupation and duties, plus the manager and state-law restrictions.
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Major Disney's $233 million Measure L settlement receives final approval#
The court filed final approval and judgment on September 16, 2025 for the $233 million Grace settlement. The agreement identifies $179.6 million for wage relief and $17.5 million in PAGA penalties within the overall settlement; it does not constitute an admission of liability. The 2023 appellate ruling held that the particular reimbursement agreement gave a contingent right to a tax rebate under Anaheim’s Measure L.
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LA's $22.50 hotel wage takes effect after referendum challenge fails#
The City Clerk found the referendum petition against the Olympic Wage ordinance had insufficient valid signatures; the $22.50 hotel worker rate (suspended since June 27) took effect September 8. Santa Monica's matching rate snapped to $22.50 the same day.
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Major DC Council scales back Initiative 82's tipped-wage phase-out#
The amended schedule kept the tipped cash floor at $10.00 through June 30, 2026, then 56% of the full minimum from July 1, 2026 ($10.30 against $18.40). It reaches 60% in July 2028, 65% in 2030, 70% in 2032, and 75% in 2034. The first jump is four percentage points; later steps are five. The enacted schedule retains a 25% credit thereafter.
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DOL relaunches the PAID self-audit program#
The revived Payroll Audit Independent Determination program lets employers self-report FLSA (and now FMLA) violations and settle back wages under WHD supervision without liquidated damages or penalties — a meaningful self-correction option for hotel operators that discover tip-pool or overtime errors.
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Major OBBBA signed: tips and overtime deductions, §45B spa expansion#
The One Big Beautiful Bill Act created deductions from taxable income for qualified tips (up to $25,000) and qualified FLSA overtime premiums (up to $12,500, or $25,000 jointly) for 2025–2028, subject to the statutory conditions. These are additional deductions below adjusted gross income, not above-the-line deductions. The Act also expanded §45B to specified beauty services. Tips and overtime remain subject to the applicable employment taxes.
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Major New York limits damages for first-time pay-frequency violations#
The May 2025 amendment to Labor Law §198 limits the specified frequency-of-pay remedy to lost interest when full wages were regularly paid at least semi-monthly. The repeat-violation liquidated-damages path requires the statute’s qualifying final, non-reviewable prior finding and subsequent conduct involving employees performing the same work. The weekly-pay obligation remains subject to §191’s coverage and authorization rules.
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DOL stops enforcing the 2024 independent-contractor rule#
Field Assistance Bulletin 2025-1 directs investigators to apply the pre-2024 economic-reality framework (Fact Sheet #13). The 2024 rule remains on the books for private litigation until the pending rescission finalizes.
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EO 14026 federal contractor minimum wage rescinded#
The $17.75 contractor minimum is gone. Legacy contracts (2015–January 2022) revert to EO 13658; newer contracts are governed by SCA prevailing wages and the FLSA. Concessioner lodges on federal lands should confirm which instrument governs before adjusting pay.
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Major Michigan rewrites its tipped-wage future after Mothering Justice#
SB 8 preserved the tip credit that the restored 2018 initiative would have eliminated: the minimum wage steps to $15.00 by 2027 (then CPI), while the tipped percentage climbs from 38% to a permanent 50% by 2031 ($5.49 cash at the 2026 40% step). Violations of the tipped scheme carry a civil fine up to $2,500.
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DOL opinion letter: managers may never take from tip pools#
FLSA2025-1 applies the combined executive duties test to managers and supervisors for tip-retention purposes; an isolated supervisory task does not by itself complete that test. Employees who meet the test cannot receive other employees’ tips from a pool. The exception for tips from service directly and solely provided is separate.
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Hyatt settles first housekeeper-workload class action for $2.25M#
The Hyatt Regency Long Beach settlement resolved the first class action under a local housekeeper workload law (Long Beach's Measure WW lineage): claims for double pay on days exceeding the square-footage cap, consent for 10+ hour days, and rest breaks. Workload ordinances are now a live class-action category.
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DOL restores the pre-2021 dual-jobs regulation#
Following the Fifth Circuit's vacatur of the 80/20/30 rule, DOL formally restored the 1967-era dual-jobs text (89 FR 101884): the tip credit turns on whether the employee is engaged in a tipped occupation, not on minute-counting of side work.
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Major Court vacates the 2024 overtime salary rule nationwide#
Texas v. DOL (E.D. Tex.) struck down the 2024 rule's $844 and $1,128 weekly salary thresholds and automatic updates, returning the federal floor to $684/week — later formalized by DOL's May 2026 technical amendment.
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Major Fifth Circuit vacates the 80/20/30 tip credit rule#
Restaurant Law Center v. DOL vacated the 2021 dual-jobs rule nationwide as contrary to the FLSA's text — ending the federal requirement to track tipped employees' side work in 20%/30-minute increments. State analogues (notably New York's) survive independently.
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Major California enacts PAGA reform#
The 2024 reforms generally govern actions brought on or after June 19, 2024, except those based on earlier notices. Standing, the 15% and 30% caps, cure, and limits on derivative stacking all have statutory conditions and exceptions. Qualifying reasonable steps plus cure can eliminate penalties; the employee share is 35%. An audit alone does not guarantee a cap.