
Can You Reclassify an Exempt Professional as Non-Exempt? DOL Opinion Letter FLSA2026-1 Says Yes
DOL Opinion Letter FLSA2026-1 (January 5, 2026) confirms employers may voluntarily classify an overtime-exempt learned professional as non-exempt, because non-exempt status is the FLSA default. Here's what the letter says, the three-prong exemption test under 29 CFR § 541.301, and a practical reclassification checklist for small businesses.










