Paid Leave and PFML Developments & Updates: 2025 Mid-Year Summary

Written by Erica Honig, J.D., Senior Compliance Director, Employee Benefits | Jul 14, 2025 6:35:36 PM

As the summer months of 2025 roll on, now is a good opportunity to provide employers with a mid-year summary of recent developments and updates with respect to certain state-specific (and local) paid leave and paid family and medical leave (PFML) programs for 2025.

Before we dive into the leave updates and developments for 2025, let’s first review the differences between state-mandated paid leave and PFML laws.

For clarity, state-mandated paid leave and PFML laws are separate programs that serve different purposes:

State and local paid leave laws generally require employers to provide paid time off to employees for certain reasons, including, but not limited to:
- when an employee is sick,
- when an employee’s family member is sick,
- when attending a medical appointment for an employee or their family member,
- when an employee seeks assistance if they or their family member is a victim of domestic violence, sexual assault, or stalking, and
- when an employee’s place of business or the school/daycare of the employee’s child is closed due to a public health emergency.
State PFML generally requires the applicable state, rather than the employer, to provide full or partial wage replacement to employees who need time away from work for certain reasons, including, but not limited to:
- caring for an employee’s own, or a family member’s, serious health condition,
- bonding with a new child, and
- supporting a family member who is on active military service duty.

2025 Developments

Let’s start with several recent PFML and paid leave developments in 2025, outlined below:

Leave Category	Jurisdiction	Important Date(s)	Important Details
PFML	Maryland	January 2027 and January 2028	The Maryland PFML contribution start date and benefit effective date have both been delayed until 2027 and 2028, respectively. The contribution start date for Maryland PFML was originally set for July 1, 2025. Click here for a Risk Strategies article with more information.
Paid Leave	Michigan	February 21, 2025 OR October 1, 2025 (depending on employer size)	Michigan paid sick leave changes took effect on February 21, 2025 for employers with more than 10 employees. Employers with 10 or fewer employees (defined as a “small business” under the Michigan Earned Sick Time Act) have until October 1, 2025, to comply with Michigan paid leave sick requirements. Click here for a Risk Strategies article with more information.
Paid Leave	Philadelphia	May 27, 2025	Philadelphia amended certain provisions of its paid sick leave ordinance, including: A definition of “tipped employee” was added^[1] Clarification of the calculation of hourly sick leave pay for tipped employees^[2] Employers are no longer required to include a Philadelphia paid sick leave notice in employee handbooks Employers must now keep records of hours of Philadelphia paid sick leave taken and sick leave payments made for three years instead of two. As a reminder, the Philadelphia paid sick leave ordinance applies to all employers with one or more employees in Philadelphia.
Paid Leave	Alaska	July 1, 2025	Paid sick leave became effective in Alaska on July 1, 2025. Click here for a Risk Strategies article with more details.
Paid Leave For Certain Public Employees	Alabama	July 1, 2025	Effective July 1, 2025, Alabama provides paid parental leave for eligible public employees, including teachers and state workers, under the Alabama Public Employee Paid Parental Leave Act of 2025. Click here for more details.
Paid Prenatal Leave	New York City	July 2, 2025	Effective July 2, 2025, New York City’s Earned Safe and Sick Time Act (NYC ESSTA) rules have been amended to align with the New York State paid prenatal leave (PPL) law, both of which apply to employers of all sizes. Click here for a Risk Strategies article for more information on the New York State PPL. Review the key items below for NYC ESSTA paid prenatal leave rules for New York City employers to be aware of (and note that these ESSTA rules are different from the New York State PPL rules): Pay Statement Notices: Employers need to inform employees who’ve used PPL of the amount used during the relevant pay period and how much PPL they have remaining. This information may be provided on the employees’ pay stubs or other written materials. Recordkeeping: Employers need to maintain PPL records for each employee, including the date and time the employee used PPL and the amount used during each pay period. Written Policy: Employers must maintain a written PPL policy and—as with ESSTA—distribute it to new employees upon hire, to all employees within 14 days of any changes to the policy, and upon an employee’s request. Documentation: Employers may require written documentation that leave of more than three consecutive days was used for an authorized purpose. Documentation signed by a licensed health care provider is considered reasonable documentation here. NYC published updated FAQs (here) and a Notice of Employee Rights. Employers should provide this notice to all employees and post it in an area that is visible and accessible to employees.
Paid Leave	Missouri	August 28, 2025	Missouri paid sick leave law requirements went into effect on May 1, 2025, and were subsequently repealed in short order by the Missouri General Assembly on May 14, 2025. The repeal will be effective on August 28, 2025. Click here for a Risk Strategies article with more details.
PFML	Connecticut	October 1, 2025	The Connecticut Paid Leave and Connecticut Family Leave programs (state PFML and FMLA) will be expanded to include certain school employees who were previously excluded. To qualify, employees must: (1) work for either a public school operator or a nonpublic school; (2) hold a position that does not require a professional license; (3) have earned at least $2,325 in their highest earning quarter within the base period; and (4) have been employed by the school for at least 12 weeks. Schools must register with the Connecticut Paid Leave program and begin deducting 0.5% contributions from the wages of eligible employees and remit those contributions on a quarterly basis. Click here for more information.
Paid Leave	Nebraska	October 1, 2025	Paid sick leave becomes effective in Nebraska on October 1, 2025. Click here for a Risk Strategies article with more details and important updates.

2026 Developments

See what’s ahead on the horizon for 2026, detailed below:

Leave Category	Jurisdiction	Important Date(s)	Important Details
PFML	Colorado	January 1, 2026	Beginning January 1, 2026, individuals will be eligible for up to twelve extra weeks of Colorado PFML benefits if their child receives inpatient care in a neonatal intensive care unit (NICU), applicable for the duration of the NICU stay. Additionally, the CO PFML premium for employees will be reduced from 0.9% of wages to 0.88% of wages, effective January 1, 2026. Click here for more information and here for a refresher article on Colorado PFML.
PFML	Delaware	January 1, 2026	Delaware PFML benefit effective date is January 1, 2026. Click here for a Risk Strategies article with more details.
PFML	Minnesota	January 1, 2026	The start date for Minnesota PFML employer and employee contributions and benefit effective date is January 1, 2026. Click here for a Risk Strategies article with more details.
PFML	Rhode Island	January 1, 2026	State legislation signed by Governor McKee on July 1, 2025, provides paid medical leave to full-time employees who donate an organ or bone marrow, beginning on January 1, 2026. Eligible employees are entitled to paid time off for medical evaluations, procedures, surgeries, and recovery related to the donation process, providing up to 5 days of paid leave for recovery after a bone marrow donation and up to 30 days for recovery following a living organ donation.
PFML	Washington State	January 1, 2026	Washington PFML has been amended by HB 1213 to provide expanded employee protections, effective January 1, 2026. Click on the section below here for more details regarding these expansions.
PFML	Maine	May 1, 2026	Maine PFML benefit effective date is May 1, 2026. Click here for a Risk Strategies article with more details.
Paid Leave	Connecticut	January 1, 2026	Paid sick leave law requirements expanded to include more employers and employees in Connecticut, specifically all employers with 11 or more employees, beginning January 1, 2026. Click here for a Risk Strategies article with more details.
Paid Leave	Oregon	January 1, 2026	Oregon amended its sick time law to permit covered workers to use their sick time to donate blood, effective January 1, 2026. Oregon Senate Bill 1108, signed into law by Governor Tina Kotek on May 28, 2025, amends the Oregon sick time law to add blood donation as a qualified reason for leave, specifically permitting employees to use their sick time “for blood donation that is made in connection with a voluntary program for the donation of blood that is approved or accredited by the American Association of Blood Banks or the American Red Cross.”
Paid Leave	Pittsburgh	January 1, 2026	The city of Pittsburgh amended its paid sick leave ordinance to provide for faster accrual and increased paid sick leave hours for eligible employees.^[3] Eligible employees will accrue Pittsburgh paid sick time at the rate of at least one hour per every 30 hours (up from 35) worked in Pittsburgh. Additionally, employers will be required to permit a maximum accrual of Pittsburgh paid sick leave: Employers with 15 employees or more: up to 72 hours per year, Employers with fewer than 15 employees: up to 48 hours per year. Currently, employers with at least 15 employees must provide 40 hours of paid sick leave, while smaller employers must provide 24 hours of paid sick leave. Click here for more information.

Washington State PFML Expansions (Effective January 1, 2026)

Job Protection Rights: Currently, the job protection rights under state PFML law apply only to employees who:
- Work for an employer with at least 50 employees;
- Have been employed by the employer for at least 12 months; and
- Worked for the employer at least 1,250 hours during the 12 months immediately preceding the leave.
HB 1213 lowers the employer size threshold for job protection rights, and provides an employee with job protection if they began employment with a qualifying employer at least 180 calendar days before taking leave, rather than the current 1,250 hours/12 months requirement.

Additionally, the job restoration requirement will apply to employers with fewer than 50 employees, under a phased-in timeline detailed below:
- 25 or more employees: beginning Jan. 1, 2026;
- 15 or more employees: beginning Jan. 1, 2027; and
- 8 or more employees: beginning Jan. 1, 2028.
Stacking Limits: Permits employers to prevent stacking of certain job protection rights by extending employment protection in the state PFML program to periods of unpaid leave protected by the federal Family and Medical Leave Act (FMLA), as long as the employer provides certain notices to the employee, and providing that employment protection expires after certain periods. Currently, employers may not count FMLA leave toward the total amount of leave entitled to state PFML job protections if the employee is not taking state PFML leave concurrently with FMLA leave.
Health Coverage Continuation: HB 1213 expands health care coverage protection during any period in which an employee receives PFML Program benefits and is also entitled to employment protection. Currently, health coverage must be continued for the duration of state PFML if there is at least one day of overlap with federal FMLA leave.
Minimum Leave Increments: HB 1213 changes the minimum leave increment to take state PFML to four consecutive hours from the current eight consecutive hours increment.

State Unpaid Leave Developments

While the developments highlighted above deal with paid leave, be sure to review the state unpaid leave updates below:

Indiana: Effective July 1, 2025 under SB 409, Indiana employers must permit employees to take unpaid time off to attend a school conference or meeting for their child, subject to certain documentation and scheduling requirements.
Maryland: Beginning October 1, 2025, Maryland employers covered by federal FMLA will no longer be required to comply with the Maryland Parental Leave Act*. Senate Bill 785 amends the definition of “employer” under the Maryland unpaid parental leave law to exclude employers covered by the federal FMLA. This change is intended to reduce redundancy between federal and state unpaid leave laws and simplify compliance for employers.

* The Maryland Parental Leave Act provides an eligible employee with a total of six (6) workweeks of unpaid parental leave during any 12-month period for the birth of a child of the employee; or the placement of a child with the employee for adoption or foster care. An “eligible employee” is one who is employed by their employer for at least 12 months and 1,250 hours during the previous 12 months.
Vermont: New legislation, effective July 1, 2025, expands the protections under the state unpaid Parental and Family Leave Act. Specifically, the legislation expands:
- the definition of a family member,
- coverage for certain professions,
- parental leave definitions, and
- qualifying reasons to take unpaid leave.
Click here for more details.
Washington State: Beginning January 1, 2026, Washington State’s Domestic Violence Leave is amended to include employees (or their family members) who are victims of a “hate crime” as defined in SB 5101.
Click here for more details on the Washington State Domestic Violence Leave Law providing unpaid leave, along with other job accommodations and protections, to employees (or qualifying family members) experiencing domestic violence, sexual assault, or stalking.

Employer Action

Employers, particularly multistate employers, are advised to pay close attention to any paid (or unpaid) leave-related developments that could impact their employees working in the jurisdictions detailed above. These employers are encouraged to work with their leave advisors/consultants and employment/labor counsel to:

Review and update their leave policies/handbooks, procedures, and practices, as necessary
Review and update attendance and payroll systems, as necessary
Train Human Resources team members and other employees who manage employee leaves regarding these updates
Communicate any applicable paid leave/PFML updates to employees in a timely and transparent manner

Risk Strategies helps employers navigate the continually evolving and complex state paid leave and PFML landscape. Contact us directly here.

[1] Tipped employee is defined here as "An employee who customarily and regularly receives more than fifty dollars ($50) a month in tips from the same employment."

[2] To calculate paid sick time for a Tipped Employee, as defined above, the hourly rate of pay shall be the numerical average of (1) the hourly wage for Standard Occupational Classification (SOC) Code 35- 3011 “Bartenders,” (2) the hourly wage for SOC 35-3031 “Waiters & Waitresses,” and (3) the hourly wage for SOC 35-9011 “Dining Room & Cafeteria Attendants & Bartender Helpers,” all as published for Philadelphia County by the Pennsylvania Department of Labor and Industry.

[3] Eligible employee under the Pittsburgh paid sick leave ordinance means an individual employed by an employer who performs work within the geographic boundaries of the City of Pittsburgh for at least 35 hours in a calendar year.

View full post