What’s New in HR Compliance This January

News January 12, 2026

EEO-1 Pay Data Reporting Deadline:

Massachusetts employers with 100 or more employees must prepare to file their annual state workforce pay data report by February 2, 2026, due to the state’s pay transparency law. Covered employers satisfy this requirement by submitting their most recent EEO-1 report to the Commonwealth, typically the same report they file with the EEOC. These reporting obligations are in addition to other pay transparency requirements under the law. Failing to file accurate, complete reports by the deadline could result in state enforcement actions or civil penalties.
Resource: JacksonLewis – Massachusetts Pay Reporting Deadline: Are You Ready for February 2, 2026?

OSHA 300A Posting Requirement

Employers must post their 300A summary of injuries and illnesses recorded in 2025. This posting at your workplace must be visible to all employees between February 1 and April 30, 2026.

Resources:

• OSHA’s Calendar of Events
• Recording | Occupational Safety and Health Administration

2026 Mileage Rate Changes

On December 29, the Internal Revenue Service announced that the optional standard mileage rate for business use of automobiles will increase by 2.5 cents in 2026, while the mileage rate for medical purposes will decrease by half a cent, reflecting updated cost data and annual inflation adjustments. Read more.

DOL Wage & Hour Division Issues New Opinion Letters

The U.S. Department of Labor’s Wage and Hour Division announced today that it has issued 6 new opinion letters to help promote clarity, consistency, and transparency in the application of federal labor standards:

• FLSA2026-1: Whether an employee’s role meets the criteria for the learned professional exemption under section 13(a)(1) of the FLSA, and, if so, whether an employer is nevertheless permitted to reclassify the employee as non-exempt.
• FLSA2026-2: Whether section 7(e) of the FLSA permits an employer to exclude certain bonus payments from an employee’s regular rate of pay. The letter also addresses how to include these payments in the calculation of employee overtime premiums if the payments must be included in an employee’s regular rate of pay.
• FLSA2026-3: Whether a union and employer can enter into a collective bargaining agreement that mandates a 15-minute “roll call” prior to each scheduled shift but excludes that time when calculating overtime premiums under the FLSA.
• FLSA2026-4: Whether, for purposes of the overtime exemption for certain commissioned employees in section 7(i) of the FLSA, an employer in a jurisdiction in which the state minimum wage exceeds the federal minimum wage must use the federal minimum wage, or alternatively, the higher state minimum wage, to determine whether it has satisfied the minimum pay standard in section 7(i)(1), and whether tips are deemed compensation for purposes of section 7(i)(2)’s requirement that more than half the employee’s compensation consist of commissions.
• FMLA2026-1: How a school closure of less than a full week impacts the amount of leave a school employee uses under the FMLA.
• FMLA2026-2: Whether FMLA leave may be used for time spent traveling to or from medical appointments, including where an employee provided the employer with medical certification from a health care provider that confirms the employee’s need for the appointment, but the certification does not address travel to or from the appointment.

Opinion letters provide official written interpretations from the division, explaining how laws apply to specific factual circumstances presented by individuals or organizations.

In June, Deputy Secretary of Labor Keith Sonderling announced the launch of the department’s opinion letter program. This program expands the department’s longstanding commitment to providing meaningful compliance assistance that helps workers, employers, and other stakeholders understand how federal labor laws apply in specific workplace situations.

The public is encouraged to use the division’s new opinion letters page to explore past guidance and submit new requests. The division will exercise discretion in determining whether and how it will respond to each request, which will focus primarily on attempting to address issues of broad-based concern.