Paid Sick Leave Expands in 2025: What Employers Need to Know

Richard Liu
May 2
4 min read

In 2025, several states have enacted or expanded paid sick leave laws, creating new compliance obligations for employers. Whether your business operates in one state or across multiple jurisdictions, it’s important to understand the specific requirements and prepare accordingly. Below is a summary of key developments and practical guidance for employers.

New Statewide Paid Sick Leave Requirements

1. Missouri

Effective Date: May 1, 2025
Accrual Rate: 1 hour of paid sick leave for every 30 hours worked
Usage Cap:
- 40 hours annually for employers with fewer than 15 employees
- 56 hours annually for employers with 15 or more employees
Carryover: Employees may carry over up to 80 hours to the next benefit year. Alternatively, employers may pay out unused leave (up to 80 hours) at year-end and frontload the required amount.
Frontloading: Permitted. If the full amount is frontloaded, carryover is not required.
Waiting Period: Up to 90 days for new employees before using accrued leave
Compliance Note: Written notice must be provided to current employees by April 15, 2025, and to new hires within 14 days of hire. The notice must be in 14-point font on a single 8.5" x 11" sheet and include accrual rates, anti-retaliation rights, and contact information for the Missouri Department of Labor. Additionally, employers must display workplace posters detailing employee rights.

2. Alaska

Effective Date: July 1, 2025
Accrual Rate: 1 hour of paid sick leave for every 30 hours worked
Usage Cap:
- 40 hours annually for employers with fewer than 15 employees
- 56 hours annually for employers with 15 or more employees
Carryover: No limit on carryover
Frontloading: The law does not explicitly address frontloading; employers should consult legal counsel before implementing this approach.
Waiting Period: No waiting period. Employees may begin using accrued leave as soon as it is earned.
Compliance Note: Employers must provide written notice to employees either at the start of employment or by July 31, 2025, whichever is later, outlining their rights and protections.

3. Nebraska

Effective Date: October 1, 2025
Accrual Rate: 1 hour of paid sick leave for every 30 hours worked
Usage Cap:
- 40 hours annually for employers with fewer than 20 employees
- 56 hours annually for employers with 20 or more employees
Carryover: No limit on carryover
Frontloading: Permitted. If the full amount is frontloaded, carryover is not required.
Waiting Period: Up to 90 days for new employees before using accrued leave
Compliance note: Written notice must be provided to employees by September 15, 2025, or upon hire thereafter. A workplace poster must be displayed or sent electronically if there is no physical location. The Nebraska Department of Labor will issue model notices and posters by mid-September 2025.

Amendments to Existing State Laws

1. Connecticut

Effective Date: January 1, 2025
Key Change:
- Expanded Employer Coverage:
  - Applies to employers with 25+ employees in 2025
  - Expands to 11+ employees in 2026
  - Applies to all employers in 2027
- Broadened Employee Eligibility: No longer limited to service workers
Accrual and Usage:
- Accrue 1 hour per 30 hours worked, up to 40 hours/year
Carryover: Allowed up to the annual usage cap
Waiting Period: Employees may begin using accrued leave after 120 calendar days of employment. This waiting period is mandatory and may not be waived by the employer.
Frontloading: Permitted. If the full amount is frontloaded, carryover is not required.
Compliance Note: Employers must provide written notice by January 1, 2025 (or upon hire), and post notice in the workplace or provide it electronically for remote workers.

2. Michigan

Effective Date: February 21, 2025
Key Changes:
- Replaces Previous Law: The Earned Sick Time Act (ESTA) replaces the Paid Medical Leave Act.
- Expanded Employer Coverage: Applies to all employers, regardless of size.
- Broadened Employee Eligibility: Covers nearly all employees, including exempt and part-time workers.
Accrual and Usage:
- Accrue 1 hour per 30 hours worked
Use caps:
- Up to 40 hours/year (≤10 employees)
- Up to 72 hours/year (>10 employees)
Carryover: Allowed up to the annual usage cap
Waiting Period: Up to 90 days for new employees before using accrued leave
Frontloading: Permitted. If the full amount is frontloaded, carryover is not required.
Compliance Note: Employers must provide written notice by January 1, 2025, or upon hire, and post notice in the workplace or provide it electronically for remote workers.

What Employers Should Do Now

1. Assess Current Policies

Review your existing sick leave policies and determine whether updates are required to comply with the new or revised state laws. Where frontloading is allowed, consider whether it offers administrative advantages over the accrual method.

2. Update Employee Handbooks and Notices

Ensure your written policies are updated to reflect state-specific rules. Multi-state employers should determine whether to use a single comprehensive policy or include state-specific addenda. Confirm that required notices and workplace posters are displayed as mandated.

3. Configure Payroll and Leave Systems

Your HR or payroll system must accurately track leave accrual, usage, and carryover. Some states also require employers to report available sick leave balances on employee paystubs.

4. Train Supervisors and HR Staff

Managers should understand when leave may be used, documentation rules, anti-retaliation provisions, and when to escalate leave requests to HR. Uniform application of policies is key to legal compliance.

5. Monitor for Further Updates

Although the above laws are scheduled to take effect in 2025, some remain subject to ongoing litigation or proposed legislative amendments. Employers should monitor guidance from state labor agencies and consult legal counsel when needed.

If you have questions about paid sick leave laws, please contact our Managing Partner, Richard Liu, Esq. at contact@consultils.com.

Disclaimer: The materials provided on this website are for general informational purposes only and do not, and are not intended to, constitute legal advice. You should not act or refrain from acting based on any information provided here. Please consult with your own legal counsel regarding your specific situation and legal questions.

Richard Liu, Esq. is the Managing Counsel of ILS. He serves clients as a management-side defense lawyer specializing in employment and business litigation. Richard is also an expert on litigation prevention and compliance. He regularly advises Fortune 500 companies and startups on employment, labor, and commercial matters.

Email: contact@consultils.com | Phone: 626-344-8949