Joint Employer Status under the Fair Labor Standards Act, Family and Medical Leave Act, and Migrant and Seasonal Agricultural Worker Protection Act
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- Title
- Joint Employer Status under the Fair Labor Standards Act, Family and Medical Leave Act, and Migrant and Seasonal Agricultural Worker Protection Act
- Posted
- Apr 23, 2026
- Comment period
- Apr 23, 2026 – Jun 23, 2026
- FR Doc
- 2026-07959
- CFR
- 29 CFR Parts 500, 780, 791, and 825
- Topics
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Stance breakdown
Who commented
Breakdown by commenter type.
Comments over time
Weekly arrivals, stacked by stance.
Support × commenter type
How each type splits across stance.
Issues raised
The docket's canonical issues. Select one to browse its comments.
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Choose up to five.
| Organization | Joint employer status factors | Contractor pay and benefits | Labor violations and human trafficking |
|---|---|---|---|
Bloomin' Blinds BusinessSupport Kristopher Stuart, CEO of Bloomin' Blinds Franchise Corp., supports the proposed rule but requests further clarification | · | · | |
California Farm Bureau AdvocacySupport The California Farm Bureau supports the proposed rule because it provides a clearer, more straightforward four-factor te | · | · | |
Center for Law and Social Policy AdvocacyOppose The Center for Law and Social Policy (CLASP) opposes the proposed rule, arguing that it improperly narrows the joint emp | · | · | |
East Coast Wings + Grill BusinessSupport East Coast Wings + Grill, a restaurant franchise, supports the proposed rule but requests specific refinements to ensure | · | · | |
First Service Brands BusinessSupport FirstService Brands supports the proposed rule but requests specific clarifications to ensure that reserved contractual | · | · | |
Independent Women AdvocacySupport The Independent Women’s Center for Economic Opportunity supports the proposed rule because it reinstates a clear, consis | · | · | |
Institute for the American Worker AdvocacySupport The Institute for the American Worker (I4AW), a 501(c)(3) nonprofit, supports the Proposed Rule because it provides regu | · | · | |
Justice for Migrant Women AdvocacyOppose Justice for Migrant Women opposes the proposed regulations, arguing that they inaccurately narrow the definition of join | · | · | |
Main Street Foundation Center for Regulatory Analysis and Engagement AdvocacySupport The Main Street Foundation’s Center for Regulatory Analysis and Engagement (CRAE) supports the Department of Labor's eff | · | · | |
McDonald's Hispanic Owner-Operators Association Trade associationSupport The McDonald’s Hispanic Owner-Operators Association (MHOA), representing Hispanic-American small business owners, suppor | · | · | |
National Association of Manufacturers Trade associationSupport The National Association of Manufacturers (NAM) supports the proposed rule, stating that it provides necessary regulator | · | · | |
National Council of Agricultural Employers (NCAE) Trade associationSupport The National Council of Agricultural Employers (NCAE) supports the Department's effort to provide clarity on joint emplo | · | · | |
Open Markets Institute AdvocacyOppose The Open Markets Institute opposes the proposed rule, arguing that it allows large corporations to evade responsibility | · | · | |
Oregon Law Center AdvocacyOppose The Oregon Law Center, a non-profit legal services organization, opposes the proposed rule because it narrows the scope | · | ||
Signatory Wall and Ceiling Contractors Alliance Trade associationOppose The Signatory Wall and Ceiling Contractors Alliance (SWACCA), a national trade association representing construction ind | · | · | |
SMART and SMACNA Trade associationOppose The International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and the Sheet Metal and Air C | · | ||
The Sunray Companies BusinessSupport The owners of Sunray Companies, a multi-brand franchise business, support the proposed joint-employer rule because it re | · | · |
4 organization-typed comments could not be identified.
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
- Jun 22, 2026Economic Policy InstituteOpposeAdvocacy📎 Attachment
The Economic Policy Institute (EPI) opposes the proposed rule, arguing that it weakens labor standards and would cost workers approximately $1 billion annually. They contend that the rule incentivizes "workplace fissuring" and increases wage theft by allowing large employers to avoid liability for violations committed by subcontractors or franchisees.
Read comment → - Jun 22, 2026SMART and SMACNAOpposeTrade association📎 Attachment
The International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and the Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) oppose the proposed rule as it is inconsistent with state and municipal laws. They argue that the construction industry should be exempt from the proposed rule and instead request the Department of Labor to establish joint and several liability for upper-tier contractors and labor brokers to ensure accountability for wage theft.
Read comment → - Jun 22, 2026Karen MulvanySupportIndividual📎 Attachment
Karen Mulvany, a family advocate, supports the Department's efforts to create a common joint employer status framework for the FLSA, FMLA, and MSPA. She requests the addition of specific examples regarding disabled adults and suggests extending the concept of primary and secondary joint employers to the FLSA to protect secondary employers from liability for wages funded by the primary employer.
Read comment → - Jun 16, 2026Adam KrouseOpposeIndividual📎 Attachment
Adam Krouse opposes the proposed rule because it narrows joint employer liability, making it harder for low-wage and gig workers to hold large "deep-pocket" companies accountable for labor violations. He argues that the proposal focuses too much on formal control while ignoring the economic reality of indirect control and common business practices like franchising and brand agreements.
Read comment → - Jun 1, 2026Anonymous AnonymousSupportIndividual
An individual is urging the Department of Labor to establish a strict joint employer standard to prevent companies from using third-party staffing agencies to depress wages. They argue that primary clients should be held liable for wages and benefits because they control the operational budgets and benefit directly from the labor of contracted workers.
Read comment →
