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Legal Update Article

Countdown to 2026: Essential Paid Leave, Earned Sick and Safe Time Updates for Minnesota Employers

Takeaways

  • Starting 01.01.26, Minnesota’s Paid Leave law provides employees up to 20 weeks of leave for qualifying reasons. The law includes immediate requirements for posting and individual notice.
  • Minneapolis and Saint Paul recently amended their Earned Sick and Safe Time ordinances to align more closely with Minnesota’s statewide law. Employees are covered under the city ordinances if they are expected to work at least 80 hours in a year within the respective city’s limits. Employers with employees in Saint Paul also must accommodate leave requests related to harassment, even if such requests would not qualify under state law.
  • Employers should review their existing policies now to ensure alignment with the new requirements.

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Minnesota employers face new requirements under the state’s Paid Leave law. Employers with employees in Minneapolis and Saint Paul also must comply with those cities’ amendments to their Earned Sick and Safe Time ordinances.

Minnesota Paid Leave

Minnesota’s Paid Leave law takes effect on Jan. 1, 2026. This program provides job protections and partial wage replacement to employees who take leave for qualifying reasons. Eligible employees can take up to 12 weeks of medical leave and up to 12 weeks of family leave within a 12-month period, with a combined maximum of 20 weeks.

Upcoming Deadlines

Employers are required to post in a conspicuous place on each of its premises a workplace poster developed by the Commissioner of the Minnesota Department of Employment and Economic Development. The notice must be posted in English and each language that is the primary language of at least five employees or independent contractors, if the poster is available from the Paid Leave Division.

Additionally, by Dec. 1, 2025, employers must provide individual notice to each employee about the availability of Paid Leave benefits. For all new hires after Dec. 1, 2025, the individual notice must be provided to the employee not more than 30 days from the beginning date of the employee’s employment.

The Paid Leave Division has published the required poster and template notices — available in English and multiple languages — for both the state plan and approved equivalent plans.

Employers’ Next Steps

Employers should review their existing policies related to paid time off benefits and leaves of absence to ensure alignment with Paid Leave requirements. Additionally, employers should consider adopting a Paid Leave policy to clearly inform employees about the benefit and reconcile it with current company benefits and other leave programs.

Updates to Minneapolis and St. Paul Earned Sick and Safe Time Ordinances

Both Minneapolis and Saint Paul recently amended their Earned Sick and Safe Time ordinances to align more closely with Minnesota’s recently amended statewide law. The Saint Paul amendments went into effect on Nov. 16, 2025, with Minneapolis’ taking effect on Dec. 31, 2025.

Changes include:

Employee Coverage

Employees are covered under the city ordinances if they are anticipated to work at least 80 hours in a year in Minneapolis or Saint Paul, a threshold that mirrors the state’s standard.

Documentation

Consistent with Minnesota’s statewide law, both city ordinances allow employers to request reasonable documentation that the absence was taken for a covered reason after absences of more than two consecutive scheduled workdays — a change from the previous threshold of more than three consecutive days.

Reasons for Use

Following the state’s lead, Minneapolis and Saint Paul expanded the qualifying reasons for Earned Sick and Safe Time to include arrangements for or to attend funeral services or a memorial, as well as to address financial or legal matters that arise after the death of a qualifying family member.

In addition, although Saint Paul’s ordinance previously mirrored the State law on safety-related uses (such as domestic abuse, sexual assault, or stalking) the recent amendments add harassment as a standalone qualifying use. Employers with employees in Saint Paul must be prepared to accommodate leave requests related to harassment, even if such requests would not qualify under state law.

Increments of Use

Both cities have aligned their increments-of-use provision with the statewide requirements. Employees may use Earned Sick and Safe Time in the same increments for which they are paid. Employers are not required to allow leave in increments smaller than 15 minutes, and they cannot require employees to use more than four hours at a time.

These changes bring greater consistency between local ordinances and state law, reducing compliance complexity. Employers operating in either city should review their policies and practices to ensure compliance ahead of the effective dates. Employers should also consider updating employee handbooks, payroll systems, and training materials accordingly.

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Now is a good time to review policies and practices and implement strong compliance programs. Jackson Lewis attorneys are available to assist companies in training and other compliance efforts.

© Jackson Lewis P.C. This material is provided for informational purposes only. It is not intended to constitute legal advice nor does it create a client-lawyer relationship between Jackson Lewis and any recipient. Recipients should consult with counsel before taking any actions based on the information contained within this material. This material may be considered attorney advertising in some jurisdictions. Prior results do not guarantee a similar outcome. 

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