Connecticut Employers: 2025 Paid Leave

Employers with employees in Connecticut need to be aware of Connecticut’s recently enacted revision to Public Act No. 24-8, which broadens the scope of paid sick leave requirements, making it applicable to a broader range of businesses and employees. Employers should review their current policies and bring them into compliance with this new revision.

Key Provisions of the Act:

1. Expanded Definition of Employers

As many employers know, Connecticut’s paid sick leave previously only applied to employers with 50 or more “service workers” (as previously defined in the statute) but has now been expanded. Under the revision, the definition of an employer will gradually encompass more businesses:

• January 1, 2025: Employers with 25 or more employees.
• January 1, 2026: Employers with 11 or more employees.
• January 1, 2027: Employers with one or more employees.

If you are currently an employer near the employee threshold, the determination of applicability will be the payroll for the week of January 1 (each year). While the previous version of the act included exclusions for certain manufacturers and nonprofits, such exemptions have been eliminated. There is now only a limited exclusion for certain construction-related employers with collective bargaining agreements.

2. Coverage for (Almost) All Employees

This expansion marks a significant shift, as the act will apply to all employees, not just those in service roles. There is, however, a limited exception for seasonal employees—those who work fewer than 120 days in a calendar year—who will not be covered under this statute.

3. Accrual of Sick Leave

Under the expansion, employers must provide at least one hour of paid sick leave for every 30 hours worked, capped at a maximum of 40 hours per year. Employers may offer more than this minimum but must adhere to this baseline.

4. Carryover Provisions

Employees can carry over accrued sick leave from one year to the next. However, employers can limit the usage of accrued sick leave to 40 hours per year. Alternatively, businesses can opt to provide a fresh 40-hour bank of sick leave at the beginning of each year, instead of providing carry over, provided that the leave meets the requirements of the law and is immediately available for employee use.

5. Conditions for Leave Use

The revision also expands the permitted reasons for taking paid sick leave. Employees can use their sick leave not only for their own health needs but also to care for a family member, attend a medical appointment with a family member, or respond to public health emergencies that impact caregiving situations, such as school closures. Additionally, the revision removes foreseeable notice and documentation requirements. This means an employer cannot require an employee to provide documentation that the leave is being taken for a permitted purpose.

6. No Replacement Requirement

Importantly, employers cannot require employees to find a replacement to cover their duties while on sick leave.

Implications for Employers and Employees

The enactment of Public Act No. 24-8 will significantly impact Connecticut employers who may not currently be offering all employees some form of paid leave. By expanding the pool of covered employees and providing more flexible sick leave options, the law will touch nearly every employee and employer throughout the state. Employers will need to adjust their policies and practices to comply with the new requirements, ensuring that employees are aware of their rights and benefits under the law.

Some areas employers should review if they are currently providing employees with paid leave that they intend to use to meet their obligations under this revised standard include:

• Does your current leave policy require the employee to find a replacement while out? If so, that would be impermissible under the amended statute and should be removed.
• Does your handbook include any language where absences may be used adversely against an employee during review? No employer may retaliate against an employee for using paid sick leave. Therefore, no language can be included where absences are used adversely against an employee.
• Does your handbook require documentation to certify the need for leave? That will be impermissible under the revised statute and should be removed.
• Do you have a use it or lose it policy? The policy should be adjusted so employees can carry over accrued time unless a lump sum is provided at the start of each new year.
• Does your current accrual rate comply with the new amended statute? Ensure it includes at least one hour of paid sick leave for every 30 hours worked.
• Finally, does your policy clearly outline eligible uses? Ensure that it details that employees can use sick leave for themselves or their families and includes all expanded reasons such as responding to public health emergencies.

In addition to the above, the statute provides posting and notice requirements. Employers must continue displaying posters regarding paid sick leave in English and Spanish; however, they must now also provide written notice to each employee by Jan. 1, 2025, or at the date of hire, whichever is later. Finally, employers must also retain sick time records for three years, which include the number of hours accrued or provided to the employee and the number of hours used by the employee during the calendar year.

Employers with questions about their obligations under this revised statute should reach out to a member of Verrill’s Employment and Labor group.