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Productivity 10 min read Feb 25, 2026

FLSA Overtime Rules for Contractors

Federal and state overtime law every construction and industrial employer must know

The Fair Labor Standards Act sets the baseline for overtime pay in the United States: any non-exempt employee who works more than 40 hours in a single workweek must be paid at 1.5× their regular rate for every hour beyond 40. That sounds simple until you layer on state daily overtime rules, prevailing wage fringe interactions, salaried-exempt misclassifications, and anti-pyramiding clauses that trip up even experienced payroll departments.

Contractors face unique challenges because crews move between states, work variable schedules during shutdowns and turnarounds, and often blend straight-time, overtime, and premium pay on a single check. This guide breaks down the federal floor, the state rules that raise it, and the mistakes that generate DOL back-pay orders averaging $1,200 per affected worker.

Federal FLSA Overtime Basics

Under the FLSA, overtime is calculated on a workweek basis—a fixed, recurring 168-hour period that the employer defines. It does not have to start on Monday; many contractors run Sunday-through-Saturday or even mid-week starts to align with project schedules. The critical rule is that the workweek must be consistently applied and cannot be changed to avoid overtime liability.

The "regular rate" is not simply the hourly wage. It includes shift differentials, non-discretionary bonuses, piece-rate earnings, and certain per-diem payments if they are tied to hours worked rather than expenses incurred. Failing to include these in the regular rate before applying the 1.5× multiplier is the single most common FLSA violation in construction payroll. For example, a worker earning $30/hr base plus a $3/hr night differential has a regular rate of $33/hr, making overtime $49.50/hr—not $45.

The FLSA does not require overtime for working more than 8 hours in a day, working weekends, or working holidays. Those requirements come from state law or union contracts. Federal law only counts total hours in the defined workweek.

Warning: Common trap: Averaging hours across two workweeks is illegal under the FLSA (except for hospitals/nursing homes under the 8/80 rule). A worker who puts in 50 hours one week and 30 the next is owed 10 hours of overtime for the first week, even though the average is 40.
Productivity

Overtime Pay Calculator

Calculate overtime pay with federal FLSA and state-specific daily OT rules for California, Alaska, Colorado, and Nevada. Handles anti-pyramiding, prevailing wage fringe, and common schedule presets.

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State Daily Overtime Rules

Several states impose daily overtime thresholds that stack on top of the federal weekly rule. California is the most aggressive: any work beyond 8 hours in a day triggers 1.5× pay, and any work beyond 12 hours in a day triggers double time (2.0×). The 7th consecutive day in a workweek also triggers overtime for the first 8 hours and double time after that. These rules apply regardless of whether the employee exceeds 40 hours in the week.

Alaska requires 1.5× after 8 hours in a day and after 40 hours in a week. Nevada requires 1.5× after 8 hours in a day for employees making less than 1.5× the state minimum wage. Colorado enacted daily overtime effective 2022, requiring 1.5× after 12 hours in a day or 12 consecutive hours regardless of start time. Oregon has daily overtime for manufacturing workers (10 hours). Washington state has been considering daily OT legislation as well.

For contractors working across state lines, the state where the work is physically performed governs overtime rules—not the state where the employer is headquartered. A Texas-based contractor running a shutdown in California must comply with California daily OT rules for every hour worked in the state. Tracking this correctly requires job-code-level timekeeping, not just weekly totals.

California double time: At 12+ hours in a single day, California requires 2.0× the regular rate. On the 7th consecutive day of the workweek, the first 8 hours are at 1.5× and hours beyond 8 are at 2.0×. No other state currently mandates double time.

Anti-Pyramiding Explained

Anti-pyramiding prevents an employee from stacking multiple overtime premiums on the same hour. Without an anti-pyramiding clause, a worker in California who works 10 hours on a Saturday (the 7th day) could theoretically claim daily overtime (hours 9–10), 7th-day overtime (all hours), and weekly overtime if over 40—tripling the premium on some hours.

Most collective bargaining agreements and many state laws include anti-pyramiding provisions that say once an hour has been compensated at a premium rate under one rule, it cannot be counted again under another. The highest applicable rate applies to that hour, and the hour counts toward weekly totals at its premium-paid status. For example, if daily OT at 1.5× has already been paid for hours 9 and 10 on Tuesday, those same hours are not double-counted toward the weekly 40-hour threshold for additional OT. The worker still gets 1.5× for those hours, but the employer does not owe a second premium.

Where it gets tricky is union contracts that intentionally allow pyramiding for specific scenarios (holiday overtime worked on a 7th day, for example). Always read the CBA language carefully. If the contract is silent on pyramiding, the default depends on state law and DOL interpretation.

Tip: Practical rule: Pay the highest premium that applies to each hour, count that hour as "premium-paid," and do not apply a second premium to it. Document which rule triggered the premium in your payroll records.

Common Contractor Violations

The Department of Labor's Wage and Hour Division recovers over $300 million annually in back wages, and construction consistently ranks among the top industries for violations. The most frequent mistakes are misclassifying workers as independent contractors (1099 vs W-2), failing to include shift differentials and per diem in the regular rate, averaging hours across a pay period instead of calculating weekly, and not paying for travel time between job sites during the workday.

Another common trap involves "comp time" in lieu of overtime pay. Private-sector employers cannot offer compensatory time off instead of overtime wages under the FLSA. Some contractors try to give workers a day off the following week to offset long hours this week—that is illegal. Government employers have a narrow comp-time exception, but private contractors do not.

Willful violations carry penalties of up to $2,074 per violation (adjusted annually for inflation), plus liquidated damages equal to the back wages owed, effectively doubling the liability. Criminal penalties including fines up to $10,000 and imprisonment apply to repeat willful violators. The statute of limitations is 2 years for standard violations and 3 years for willful ones.

Warning: 1099 misclassification: Calling a worker an "independent contractor" does not make them one. The DOL uses an economic-reality test focusing on control, investment, permanence, and skill. Misclassification triggers back OT, back taxes, and penalties.
Productivity

Break & Lunch Compliance Checker

Check meal and rest break requirements for all 50 states. Shows required breaks for your shift length, premium pay penalties for violations, and federal FLSA rules.

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How to Audit Your Payroll

A quarterly internal audit takes about two hours and can prevent six-figure back-pay liability. Start by pulling a sample of 10–15 employees who worked overtime in the last quarter. For each, verify that the regular rate includes all required components: base hourly rate, shift differentials, non-discretionary bonuses (prorated across the hours worked), and any taxable per-diem amounts. Recalculate the overtime rate and compare it to what was actually paid.

Next, check that your workweek definition is documented and consistently applied. Review any weeks where hours were close to 40 and verify that all hours were captured—including pre-shift safety meetings, post-shift cleanup, and travel between sites. If you operate in a daily-OT state, verify that daily hours are tracked separately from weekly totals and that the correct premium was applied. Finally, spot-check any workers classified as exempt to confirm they meet the salary basis ($684/week minimum as of 2024) and duties tests for executive, administrative, or professional exemptions.

Tip: Documentation tip: Keep workweek definitions, overtime policies, and exemption analyses in writing. If the DOL audits, your first line of defense is showing that you have a documented, good-faith compliance program.
Productivity

Overtime Pay Calculator

Calculate overtime pay with federal FLSA and state-specific daily OT rules for California, Alaska, Colorado, and Nevada. Handles anti-pyramiding, prevailing wage fringe, and common schedule presets.

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Frequently Asked Questions

No. Federal law only requires overtime after 40 hours in a workweek. Daily overtime is a state-level requirement—California, Alaska, Nevada, and Colorado have daily OT thresholds. Always check the state where the work is physically performed.
Private-sector employers cannot substitute compensatory time off for overtime pay under the FLSA. Only state and local government employers may offer comp time under strict conditions (1.5 hours of comp time per overtime hour, with a cap). Private contractors must pay overtime in wages.
Yes. Travel between job sites during the workday is compensable time under the FLSA. Normal commuting from home to the first site and from the last site to home is generally not compensable, but travel from site to site during the day must be paid and counts toward the 40-hour overtime threshold.
On Davis-Bacon projects, overtime is calculated on the total prevailing wage rate (base + fringe). However, the fringe portion is paid at the straight-time rate even during overtime hours—only the base cash wage gets the 1.5× multiplier. This is a common source of payroll errors.
Employers owe back wages plus an equal amount in liquidated damages (effectively doubling the liability). Civil penalties up to $2,074 per violation apply for willful or repeated offenses. The DOL can go back 2 years (3 years for willful violations) and pursue criminal charges for repeat offenders.

Calculators Referenced in This Guide

Productivity Live

Overtime Pay Calculator

Calculate overtime pay with federal FLSA and state-specific daily OT rules for California, Alaska, Colorado, and Nevada. Handles anti-pyramiding, prevailing wage fringe, and common schedule presets.

Productivity Live

Shift Differential Calculator

Calculate night shift, weekend, and holiday differential costs for your workforce. Supports flat-dollar and percentage premiums with annual projections and what-if analysis.

Productivity Live

Overtime Cost Projection Tool

Analyze the true cost of overtime including hidden costs like turnover, fatigue incidents, FICA, and workers comp. Compares OT strategy vs hiring additional staff with break-even analysis.

Productivity Live

Davis-Bacon Prevailing Wage Calculator

Calculate Davis-Bacon prevailing wage pay with correct overtime rules where fringe stays flat. Compare cash-vs-benefits tax savings, annualize fringe credits, and compute apprentice wage steps.