On September 7, 2026, the Department of Labor (DOL) issued an opinion letter addressing certain types of volunteer activities and whether those activities should be paid labor. The letter specifically relates to a nonprofit organization that breeds and trains service dogs and whether employees can perform off-the-clock external “canine socialization.”
Nonprofits traditionally have a broader ability to utilize volunteers, including their own employees, for certain tasks than would be allowed in a for-profit organization. For-profit organizations utilizing unpaid interns or volunteers are typically extremely limited and must either work through an accredited school program that gives academic credit for the internship or limit volunteers to truly limited external volunteer activities that have no relationship to the business of the for-profit company.
Nonprofits by their very nature can and do use volunteers in a much broader array of ways, and this has been recognized by the DOL consistently. As the September letter notes, any volunteer activities performed by anyone, including existing employees, must be done “freely and without coercion, with no contemplation of pay for the volunteer services rendered, and the volunteer services are not the same type of services you employ the employees to perform.”
It is always more complicated when any institution, including a nonprofit, uses its own employees as “volunteers.” The key element of any decision is that the services for...
Jon Gosselin is one proud father in the wake of his son Collin Gosselin’s debut tell-all memoir. “First and foremost, I couldn’t be more proud of my son’s heartbreaking memoir and his mission to h...