Employment Law Alert: MORE Chicago Paid Leave & Paid Sick/Safe Leave Changes

Chicago is at it again, but this time it's good news for employers! On December 13, 2023, the Chicago City Council amended the recently enacted Chicago Paid Leave and Paid Safe Sick Leave Ordinance that we discussed in our December 1, 2023 employment law alert. As to updating personnel policies for 2024, the key changes are:

• The mandate to provide paid leave (much like PTO) to employees who work in Chicago has been extended from January 1, 2024 to July 1, 2024. Importantly, this does not change the State of Illinois' legal requirement to provide paid leave to employees eligible under the state law by January 1, 2024.
• The deadline to satisfy modified requirements for sick/safe leave has been extended from January 1, 2024 to July 1, 2024. Importantly, employers must continue to satisfy Chicago's pre-existing legal requirements to provide sick/safe leave until then.
• The employee eligibility requirements for paid leave and safe/sick leave were changed to require an employee to have worked in the City of Chicago at least 80 hours within any 120-day period (previously, it was at least 2 hours within any 2-week period).

All other requirements of the Ordinance remain effective December 31, 2023. Employers with any employee(s) working in Chicago should discuss with legal counsel how to ensure compliance with the new requirements effective December 31, 2023, and July 1, 2024.

Employers seeking further guidance may contact any of the firm’s attorneys.