The 2026 FIFA World Cup arrives in Dallas and Houston this summer, with games kicking off in each city beginning on Sunday, June 14, 2026. While employers across hospitality, transportation, security, food service, and event operations are preparing for a surge in business, they should also remain aware of potential increases in legal exposure.

The U.S. Department of Labor (“DOL”) has issued a news release saying that it will be offering compliance assistance for host-city employers, signaling regulatory attention. Texas offers employers meaningful advantages (e.g., no state income tax, no mandatory paid sick leave, and optional workers’ compensation), but federal obligations remain in force, and this event’s scale amplifies possible compliance gaps.

Here are ten employer-facing issues that warrant immediate attention in advance of this summer’s World Cup:

1. Worker Misclassification

Labeling a worker as a “contractor” does not determine their legal status. Under the Fair Labor Standards Act (“FLSA”), the “economic reality” test governs. This test looks at whether the worker is economically dependent on the employer or in business for themselves. The DOL’s Proposed 2026 Rule identifies five factors, with two “core factors” weighted more heavily: (1) the worker’s control over the work, and (2) opportunity for profit or loss based on managerial skill or investment. Three additional factors (i.e., skill required, permanence, and integration) guide the analysis when core factors diverge. Actual practice matters more than contract terms. At present, the enforcement landscape is bifurcated: the 2024 Biden Administration Rule applies in private litigation, while DOL field staff have been instructed to follow a 2008 DOL fact sheet. Texas courts, meanwhile, apply the federal economic reality test without a separate ABC test. For Texas employers during this World Cup, if your company sets schedules, supplies equipment, and dictates how work is performed, those workers are likely to be viewed as employees by the powers that be. We recommend performing a pre-event classification audit in consultation with legal counsel to mitigate risk.

2. Wage and Hour Compliance

Event workers routinely face 10- to 16-hour shifts and “off-the-clock” work, including pre-shift setup, mandatory meetings, post-event cleanup, which is pervasive in major sporting event environments. The FLSA mandates overtime pay after 40 hours per week, and Texas provides no state minimum above the $7.25 federal floor. Employers using the tip credit must provide written notice to each tipped employee before claiming it. Violations carry back wages, liquidated damages, and attorney’s fees; the DOL assessed $318 million in penalties in fiscal year 2025 alone. For these reasons, we recommend implementing tamper-resistant timekeeping systems, training supervisors to record all work, and considering use of the DOL’s Payroll Audit Independent Determination (PAID) self-reporting program as a proactive compliance tool.

3. I-9 and Immigration Compliance

Rapid onboarding of hundreds or thousands of workers multiplies I-9 error risk. Section 1 must be completed by the first day of work, and Section 2 must be completed within the subsequent three business days. Employers should be wary of requesting more or different documents than necessary or rejecting valid documents; this constitutes document abuse under 8 U.S.C. § 1324b when done for the purposes of discriminating on the basis of citizenship or national origin. Additionally, while Texas does not mandate E-Verify for private employers, employers should anticipate that ICE audits could increase during the tournament. Employers should be proactive by designating a trained I-9 compliance officer, maintaining consistent document-copying practices, and endeavoring to secure contractual indemnification from staffing agencies handling verification.

4. Discrimination and Harassment

The World Cup will bring together workers and fans from dozens of nations in two of the country’s most diverse metropolitan areas. Title VII and the Texas Commission on Human Rights Act prohibit discrimination based on national origin, religion, race, sex, and other protected characteristics. Additionally, English-only rules require documented business justification and narrow application, and employers must provide reasonable religious accommodations absent undue hardship. Employers should distribute anti-harassment policies in relevant languages, provide supervisors with national origin sensitivity training, and investigate complaints promptly, including those involving temporary workers.

5. OSHA and Heat Safety

Dallas and Houston temperatures regularly exceed 100°F during the June–July tournament window. OSHA’s General Duty Clause requires workplaces be kept free from recognized hazards, and the agency has updated its heat-focused National Emphasis Program in April 2026. As a best practice, employers should establish a written Heat Illness Prevention Plan with acclimatization schedules, mandatory water and shade provisions, and supervisor training on symptom recognition. Under the multi-employer doctrine, venue operators may be liable for hazards affecting subcontractors’ employees, making contractual safety requirements in vendor agreements essential.

6. Workers’ Compensation

Texas uniquely allows private employers to opt out of the workers’ compensation insurance system, but in doing so non-subscribers forfeit all common-law defenses, such as contributory negligence, the fellow servant rule, and assumption of the risk. Further, a staffing agency’s workers’ compensation policy does not automatically extend coverage to a client employer. For operations involving significant physical labor, subscriber status is strongly advisable, and employers using staffing agencies should get written confirmation of explicit policy coverage for their operations.

7. Leave Laws

Temporary World Cup hires are unlikely to meet the eligibility thresholds under the Family and Medical Leave Act (“FMLA”), but permanent hotel, venue, and transportation employees may request FMLA leave during peak operations. Texas has no paid sick leave law and local ordinances for that purpose have been preempted. Employers should audit FMLA-eligible employees now, build staffing redundancy through cross-training and reserve pools, and establish clear attendance policies for event workers. Voluntarily offering limited, paid sick leave during the tournament can help to encourage sick food handlers to stay home—protecting both public health and operations—and all leave requests and responses should be documented.

8. Non-Competes and Confidentiality

Broad non-competes are difficult to enforce against short-term event workers under Texas law, which requires such covenants to be “ancillary to an otherwise enforceable agreement” with reasonable limitations. Non-disclosure agreements are generally considered to be more effective because they may be readily enforced in Texas without requiring a time limitation. Employers should include the required whistleblower immunity notice under the Defend Trade Secrets Act in all agreements and ensure that no provision restricts employees from discussing wages or working conditions; the National Labor Relations Board continues to scrutinize the latter in particular.

9. Security Staffing

Security personnel present dual liability exposure: potential claims from excessive force against the public and claims from failure to prevent harm. Employers should conduct individualized background checks, follow adverse action procedures imposed by the Fair Credit Reporting Act, verify personnel hold valid licenses under the Texas Private Security Act, and provide training on deescalation and use-of-force standards.

10. Labor Relations

Before deploying temporary staff, employers should map whether and which job classifications are covered by collective bargaining agreements and ensure temporary assignments do not encroach on covered work. Employers should retain counsel to review handbooks and agreements for labor law compliance before distributing them to a large, temporary workforce.

Bottom Line

The time to build compliance infrastructure is now, before the tournament begins. Employers who invest in these practices will be best positioned to capitalize on the World Cup’s economic opportunity while limiting legal risk. Those who defer will likely find remediation far more costly than preparation. While we cannot solve the traffic congestion everyone is bracing for, we’re happy to help employers navigate the legal landscape before gridlock sets in.