When the FLSA Considers You Exempt

The short answer

The FLSA treats an employee as exempt from overtime only when salary basis, the pay threshold, and the duties test all fit — a salary or a manager title alone is never enough.

What “exempt” actually requires

Under federal law, most white-collar exemptions need three things: pay on a salary basis, pay that clears the threshold ($684/week for most categories — still the floor after the 2024 raise was vacated and rescinded), and a primary duty that matches a Part 541 category (executive, administrative, professional, computer, outside sales, or highly compensated). Computer roles may use $27.63/hour instead of the weekly salary. Outside sales has no federal minimum salary, but the “away from the office” sales duty still has to be real. Highly compensated employees need $107,432 total annual compensation plus at least one exempt duty — high pay alone is not enough.

How to screen a role before you skip overtime

  • Confirm the pay structure is a true salary (or the computer hourly / outside-sales path) — daily rates can fail even at high total pay.
  • Confirm the dollar floor for the category you are using ($684/week, $27.63/hour, or $107,432 HCE).
  • Walk the actual duties, not the job title — manage 2+ and hire/fire weight for executive; independent judgment on significant matters for administrative; real professional or computer work, not labels.
  • If any prong fails or is unclear: treat as non-exempt, track hours, pay overtime.
  • Some states set higher salary floors than federal law (research notes California, Washington, and Colorado among them) — the work state can raise the bar.

Where exemption claims break

  • The “coordinator” or “assistant manager” paid a salary who follows fixed procedures and supervises no one — fails the duties test.
  • The high earner on a daily rate — can still be non-exempt after Helix Energy (2023).
  • The inside salesperson labeled “outside sales” who works from the company office.
  • The IT help-desk role labeled “computer exempt” without systems analysis, programming, or software engineering as the primary duty.
  • Stopping time records because “they’re salaried” — if classification was wrong, missing records help the employee’s claim.

When in doubt, track the hours

Exempt is a legal status the employer has to prove — not a payroll setting. If you would struggle to explain the salary basis, the dollar floor, and the real duties to a DOL investigator, pay overtime until you can. For the full category table, vacatur history, and screening checklist, see the FLSA exemption tests deep dive.