[zonethundery]

The rule does not implement the ABC test from California. Indeed, the DOL has gone on at length about why it believes it cannot do that.

Unlike the Cal Supreme Court decision in Dynamex and the subsequent AB5 legislation, which _presumes_ a worker is an employee unless their work passes each prong of the ABC test, DOL still has the burden of proof under this rule.

Your biggest risk was actually the PRO Act, and it will never pass.

And if you have multiple clients who have limited control over how you do your work, you're a bona fide independent supplier anyway.