USA


Missouri – paid sick leave

Impact date: 1 May 2025 (but see below) Missouri passed a paid sick leave law, requiring that employees must accrue one hour of paid sick leave for every 30 hours worked. Leave is accrued from the effective date of the law or the beginning of the employee’s employment. Employers with 1-14 employees may cap accruals at 40 hours of paid leave each year. Employers with 15 or more employees may cap accruals at 56 hours of paid sick leave each year. Accrued unused sick leave must carry over to the next calendar year, subject to the usage cap of 80 hours. Sick leave can be used for the benefit of the employee’s mental and physical health, that of a family member (as defined in the statute), due to domestic violence, assault, or stalking, or due to the closure of the employee’s place of business or their child’s school or place of childcare due to a public health emergency and the like.

Employer implications/action needed Missouri voters passed a paid sick leave law in November 2024. The law was challenged in court but the Missouri Supreme Court upheld the law on 29 April 2025 and it became law with an effective date of 1 May 2025. The Missouri legislature has passed H.B. 567 which would delay the effective date until 1 January 2026 but that Bill has not yet become law. As such, employers with employees in Missouri should provide paid sick leave for those employees in accordance with this law.

Employer risk Employees are entitled to administrative remedies and a private right of action. Willful violations are a Class C misdemeanor (notice and positing violations, however, are an infraction).

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New Jersey – pay transparency

Impact date: 1 June 2025 New Jersey passed a pay transparency law that will require employers with ten or more employees over 20 or more calendar weeks who do business, employ any individual, or accept job applications within New Jersey to:

  • Disclose the hourly wage or salary range and a general description of benefits and other compensation in any job posting; and
  • Notify current employees about any opportunities for promotion that the employer has advertised internally or externally

Employer implications/action needed Employers that have ten or more employees and that do business, employ workers, or accept job applications within New Jersey should ensure that they include the required information in any job postings and communicate with current employees about any upcoming promotion opportunities.

Employer risk There is no private right of action for violations of the law, but the New Jersey Commissioner of Labor and Workforce Development may impose statutory penalties up to $300 for the first violation and up to $600 for any subsequent violation.

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Alaska – paid sick leave

Impact date: 1 July 2025 As of 1 July 2025, employees must accrue one hour of paid sick leave for every 30 hours worked. Leave is accrued from the effective date of the law or the beginning of the employee’s employment. Frontloading is not specified in the ballot measure. Employers with 1-14 employees must allow employees to accrue and use up to 40 hours (cap) of paid leave each year. Employers with 15 or more employees must allow employees to accrue and use up to 56 hours (cap) of paid sick leave per year. Unused leave must roll over from year to year subject to the usage cap. Sick leave can be used for the benefit of the employee’s mental and physical health, that of a family member (as defined in the statute), for specified purposes if the employee or their family member is the victim of domestic violence or sexual assault, to attend school meetings related to their child’s health, disability, or the effects of domestic violence, sexual assault or stalking.

Employer implications/action needed Employers with 15 or more employees in Alaska should note the new requirements and take steps to update their recruitment procedures accordingly.

Employer risk Failure to comply may result in a claim by the employee for lost wages and other damages and penalties.

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Vermont – pay transparency

Impact date: 1 July 2025 Vermont passed a pay transparency law that will require employers with at least five employees and with at least one employee in Vermont to:

  • Disclose the hourly wage or salary range in any job posting, whether online or in print and for both internal and external applicants, for roles predominantly performed for an office or work location that is physically located in Vermont and
  • Provide salary information from job applicants or current employees if a candidate asks for the salary range during the interview or after receiving a job offer

The law also prohibits employers from asking candidates about their salary history during the hiring process.

Employer implications/action needed Employers that have at least five employees and at least one employee working in Vermont should prepare to include the required information in any job postings and communicate with candidates regarding salary ranges. Employer should also refrain from asking about salary history with prospective employees and ensure any salary questions on job applications or list of interview topics are removed.

Employer risk There is no private right of action for violations of the law, but the Vermont Attorney General or State’s Attorney may impose civil penalties or require an employer to pay restitution of wages to an employee for any violations.

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Minimum wage increases – mid-year

Impact date: 1 July 2025; 30 September 2025 A number of states and localities increase their minimum wage rates on 1 July each year. States that will increase their minimum wage rate as of 1 July 2025 include: Alaska; Berkeley, CA, Emeryville, CA, Fremont, CA; Los Angeles, CA (city and county); Milpitas, CA; Pasadena, CA; San Francisco, CA; Santa Monica, CA; District of Columbia; Montgomery County, MD; Oregon (and numerous counties); and St. Paul, MN. Florida is set to increase its minimum wage rate on 30 September 2025.

Employer implications/action needed Employers should review wage rates for non-exempt employees and ensure that all such employees are being paid at or above the applicable minimum wage rate and that overtime calculations are also adjusted. In some instances, the increase in minimum wage rates can impact salary thresholds for exemption, so employers should ensure this is checked.

Employer risk Failure to pay non-exempt employees at or above the applicable minimum wage rate can result in wage claims under the FLSA and applicable state and local laws. This also applies for exempt employees who are not paid at or above the federal and applicable state salary threshold.

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Nebraska – paid sick leave

Impact date: 1 October 2025 As of 1 October 2025, individuals engaged in service to an employer (except US Government employees) must accrue one hour of paid sick leave for every 30 hours worked. Leave is accrued from the effective date of the law or the beginning of the employee’s employment. Frontloading the entire entitlement is permitted. Employers with 1-19 employees must allow employees to accrue and use up to 40 hours of paid leave each year. Employers with 20 or more employees must allow employees to accrue and use up to 56 hours of paid sick leave each year. Accrued unused sick leave must carry over to next calendar year, subject to the usage cap. Sick leave can be used for the benefit of the employee’s mental and physical health, that of a family member (as defined in the statute), or due to the closure of the employee’s place of business or their child’s school or place of childcare due to a public health emergency and the like.

Employer implications/action needed Employers with 20 or more employees in Nebraska should note the new requirements and take steps to update their recruitment procedures accordingly.

Employer risk Employers in violation may receive a citation for violations and penalties from $500 to $5,000 Employees have a private right of action with a four-year statute of limitations to recover appropriate legal and equitable relief and reasonable attorneys’ fees.

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Massachusetts – pay transparency

Impact date: 29 October 2025 Requirements under a new Act Relative to Salary Transparency include:

  • Pay range disclosures: public and private employers with 25 or more employees in Massachusetts must:
  • Disclose pay ranges in job postings
  • Provide pay ranges of positions to employees who are offered promotions or transfers to new positions with different job responsibilities and
  • On request, provide the pay range to an employee who already holds an employment position or to an applicant for such position
  • Equal employment opportunity and wage data reporting: public and private employers with 100 or more employees in Massachusetts at any time during the prior calendar year who are also subject to federal wage data reporting requirements must submit an equal employment opportunity and wage data report to the Secretary of the Commonwealth
  • Prohibition on retaliation

Employer implications/action needed Employers with 25 or more employees in Massachusetts should note and apply the new requirements.

Employer risk Although employees/applicants have no direct right to sue for non-compliance, employers that fail to comply with the new requirements risk enforcement via general attorney by injunctive or declaratory relief. In addition, they risk fines of $500 for any second violation, $1,000 for any third and $7,500-25,000 for any subsequent violations.

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Michael Woodson Partner


E: michaelwoodson@eversheds-sutherland.com T: +1 713 470 6121

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