USA
Connecticut – Paid sick leave
Impact date: 1 January 2025 for employers with 25+ employees, 1 January 2026 for employers with 11-24 employees and 1 January 2027 for employers with one-ten employees As of 1 January 2025, employers must allow employees to 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 must allow employees to accrue and use up to 40 hours of paid leave each year, which can be carried over subject to a 40-hour 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. The effective date is staggered based on the sick of the employer, as provided below.
Employer implications/action needed Employers should update policies, accruals for tracking and posters.
Employer risk Penalties and damages can be assessed for failing to comply.
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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 Employers with at least five employees and with at least one employee in Vermont must:
- 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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California – AI in the workplace
Impact date: 1 October 2025 As of 1 October 2025, employers with five or more employees must review and participate in the outcome of automated decision systems (ADS) used in making certain employment-related decisions. Employers and their agents must not use ADS decisions in a manner that discriminates or creates a disparate impact, and are responsible for reviewing the outcomes and engaging in disparate impact analyses. Records of ADS data must be retained for at least four years. Caution should be taken where the data is generated by methods such as tests and quizzes, as some such methods may constitute unlawful medical inquiries if they elicit medical information.
Employer implications/action needed Employers should update their policies and notices.
Employer risk Penalties and damages can be assessed for failing to comply with the new rules, which are contained in the Civil Rights Department regulations under the Fair Employment and Housing Act(FEHA).
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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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Illinois – Expanded dependent coverage requirements for fully insured health plans
Impact date: 1 January 2026 As of 1 January 2026, fully insured health plans in Illinois must extend coverage to eligible dependent parents and stepfathers of insured individuals, provided they reside within the health plan’s service area.
A parent or stepparent must be a “qualifying relative” under section 152(d) of the Code (i.e., be a parent/stepparent, have gross income less than the exemption amount ($5,050), receive more than half of the individual’s total financial support).
This development applies to health insurance policies issued, amended, delivered or renewed in Illinois after 1 January 2026. It does not apply to policies issued in other states, even if the employer has employees living or working in Illinois.
Self-funded and level funded plans are excluded.
Employer implications/action needed Employers with fully insured health plans in Illinois should take steps with their vendors as it pertains to enrollment of these individuals, and will need to determine their administrative strategy (i.e., requiring an attestation form or affidavit from an employee prior to enrolling a dependent parent or stepparent onto their plan).
Employer risk N/A
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Delaware – Paid family medical leave
Impact date: Employees become eligible for benefits as of 1 January 2026 As of 1 January 2025, employees who perform at least 60% of their work for their employer in Delaware, and who have worked for their employer for at least one year, 1,250 hours, are eligible for time off and benefits under the Delaware Healthy Families Act.
Employers with 10-24 employees need only allow time for parental leave, but employers with 25+ employees must allow time off for parental, family care giving, and medical leave. Leave time is up to 12 weeks per year for parental leave, and up to 6 weeks per 24-month period to care their own medical condition or that of a family member, as defined in the statute. Employees can receive up to 80% of their salary with a maximum of $900 per week (in 2026, 2027) funded by employer contributions, but employers can deduct up to 50% of the contribution from employee wages.
Employer implications/action needed Employers with ten or more employees in Delaware should update policies and practices to comply.
Employer risk Employers can be liable for penalties up to $5,000 per violation as well as lost wages and benefits.
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Maine – Paid family medical leave
Impact date: Employees become eligible for benefits as of 1 May 2026 (subject to possible delays) Contributions to the Maine Paid Family and Medical Leave Program began on 1 January 2025. Employees are eligible for benefits as of 1 May 2026.
Employees who earn at least six times the State’s Average Weekly Wage (SAWW) during the base period are eligible to take up to 12 weeks of leave for the birth, adoption, or foster care placement of a new child; to care for their own or a family member’s serious health condition; organ donation; for specified purposes related to domestic violence, sexual assault, or stalking; or the death or serious health condition of certain family members on active military duty.
The Program applies to all employers. Employees can receive up to 100% of the SAWW, which is currently $1,198.84, funded by employer contributions, but employers can deduct up to 50% of the contribution from employee wages.
Employer implications/action needed Employers with employees in Maine should update policies and practices to comply.
Employer risk Employers can be liable for penalties and damages.
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Illinois – Neonatal intensive care leave
Impact date: 1 June 2026 Under the Neonatal Intensive Care Leave Act (NICLA), when the child of an employee is a patient in a neonatal intensive care unit, Illinois employers must provide:
- Ten days of unpaid leave (employers with 16-49 employees)
- 20 days of unpaid leave (employers with 50+ employees)
Leave may be taken intermittently or consecutively, is in addition to FMLA leave and is tacked on at the end of FMLA leave. Employers may not require employees to substitute accrued paid leave prior to taking NICLA leave, and employees must be reinstated to their former position or a substantially equivalent position with no loss of benefits held or accrued prior to taking leave.
Employers may require “reasonable verification” of the child’s NICU stay but cannot request any confidential information protected by HIPAA or any other law.
Employer implications/action needed Employers with 16 or more employees in Illinois should note the new requirements and take steps to update their leave policies accordingly.
Employer risk The IDOL can impose penalties up to $5,000 per violation and can assess other damages such as unpaid wages and further penalties, with 80% of the amount collected going to the employee. Employees have 60 days from the last event constituting the alleged violation (e.g., not returning employee to prior/similar position, retaliating at a later date, or forcing employee to use paid leave) to file a claim with the IDOL or a lawsuit in court.
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Maryland – Paid family leave
Impact date: Employees become eligible for benefits as of 3 January 2028 As of 1 January 2025, delays to contributions and benefits under the Maryland Paid Family and Medical Leave Insurance Program were agreed.
Contributions to the program will begin in January 2027 and benefits will be available beginning on 3 January 2028.
The Maryland Paid Family and Medical Leave Insurance Program applies to all employers with at least one employee. Employees who have worked at least 680 hours over the four most recent quarters are eligible for up to 12 weeks of leave for the birth, adoption, or foster care placement of a new child, or to care their own medical condition or that of a family member, as defined in the statute. An additional 12 weeks may be available to care for the employees own serious medical condition or that of a family member if the initial 12 weeks was for the birth, adoption, or foster care placement of a child. Employees can receive up to 90% of their salary with a maximum of $1,000 per week funded by employer and employee contributions.
Employer implications/action needed Employers with one or more employees in Maryland should update policies and practices to comply.
Employer risk Employers can be liable for penalties up to $1,000 per violation as well as lost wages and benefits and treble damages.
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