As we reported at the end of 2024, there are a number of critical employment law developments that will affect U.S. employers in the next several months, and, for some employers, in the next several days. Though not an exhaustive list, we focus here on some key upcoming deadlines for employers in Q2 and Q3 2025.
Paid Sick Leave
- Missouri: Last Election Day, Missouri voters passed a ballot initiative requiring employers to provide employees with one hour of paid sick leave for every 30 hours worked, which leave can be capped at 40 hours per year (for employers with 1-14 employees) or 56 hours per year (for employers with 15 or more employees). By April 15, 2025, employers must provide a written notice to current employees about the new paid sick leave law, which will become effective May 1, 2025, the same date that paid sick leave must begin to accrue. New employees must receive notice of the law within fourteen (14) calendar days of commencing employment. Employers also must display a poster in the workplace informing employees about the law. (Note: The law is the subject of a pending constitutional challenge before the Missouri Supreme Court, which heard oral arguments on March 12, 2025. There is also a bill moving through the Missouri legislature to remove the paid sick leave component of the law. Despite these challenges, as of this writing, the law is still slated to go into effect on May 1, 2025.)
- Alaska: Alaska voters similarly adopted a paid sick leave law in November 2024 via ballot initiative, but the law does not become effective until July 1, 2025 (the same day the state minimum wage increases to $13/hour). Alaska employers should prepare now to provide their employees with paid sick leave at the rate of one hour for every 30 hours worked, which leave can be capped at 40 hours per year (for employers with fewer than 15 employees) or 56 hours per year (for large employers with 15 or more employees). Employers shall give written notice at the later of the commencement of employment or August 1, 2025 that, beginning July 1, 2025, they are entitled to paid sick leave and the amount of leave; the terms of its use; and that retaliation against employees for exercising their paid sick time rights is prohibited. The Alaska Department of Labor has published FAQs for employers about the law.
- Michigan: For Michigan employers that may have missed the news, the Earned Sick Time Act was reinstated, effective February 21, 2025 for employers with more than ten employees and October 1, 2025 for employers with ten or fewer employees. If Michigan employers have not already done so, they must allow employees to accrue one hour of paid sick leave for every 30 hours worked, with no accrual cap; provided, however, that employers are not required to permit an employee to use more than 40 hours per year if they employ 10 or fewer employees, or 72 hours of paid sick leave per year if they employ 11 or more employees. There is also a notice posting requirement.
- Nebraska: Last November, voters in Nebraska passed Initiative Measure 436, creating a new statewide paid sick leave law. Employees accrue one hour of leave for every 30 hours worked, with accrual caps of 40 hours per year for employers with 1-19 employees and 56 hours per year for employers with 20 or more employees. Although there is still some time to prepare before the law’s effective date (accrual of paid sick leave begins October 1, 2025), employers must provide notice to employees of the new law by September 15, 2025; however, as of this writing, the Nebraska Department of Labor has not yet published a model notice.
- City of Chicago: Pursuant to Chicago Municipal Code §§ 6-130-005 et seq., employees who work at least 80 hours for an employer in Chicago within any 120-day period are eligible to accrue one hour of paid leave and one hour of paid sick leave for every 35 hours worked in Chicago, with accrual capped at 40 hours of paid leave and 40 hours of paid sick leave per 12-month period. Payout of paid sick leave is not required, but beginning July 1, 2025, employers with 51 or more employees must pay out all unused, accrued paid leave upon termination. (Employers with 101+ employees are already subject to this requirement.)
- As a reminder: Connecticut adopted a paid sick leave law that went into effect on January 1, 2025, and New York employers were required to provide employees 20 hours of paid prenatal personal leave per year beginning January 1, 2025. New York’s COVID-19 leave law will be repealed effective July 31, 2025.
Family Leave
- Maryland: We previously reported that payroll deductions to support Maryland’s family and medical leave insurance (FAMLI) program would begin on July 1, 2025, with employers required to remit the first payments to the state in October 2025. This remains the law, and if unchanged, employee benefits will become available on July 1, 2026. However, the Maryland General Assembly recently passed a bill to further defer implementation dates for the program. If passed, the law would delay benefits eligibility to January 3, 2028. We will continue to track legislative developments, and Maryland employers also should consider registering for legislative alerts that might postpone payroll deduction requirements.
Pay Transparency
- New Jersey: Under the New Jersey Wage Transparency Act,beginning June 1, 2025, employers with ten or more employees that do business, have employees, or take applications for employment in New Jersey must make certain internal and external pay disclosures. Covered employers must disclose, in new job postings and transfer opportunities advertised externally or internally, the hourly wage or salary (or wage/salary range) and a general description of benefits and other compensation programs for which the employee would be eligible. Noncompliance with the Act carries civil penalties from $300 to $600 per violation.
- Vermont: Effective July 1, 2025, Vermont employers with five or more employees, at least one of which works in the state of Vermont, must include the compensation or range of compensation in each job advertisement. The law applies to any job posting for a position physically located in Vermont or to be filled by a remote worker outside the state who predominantly performs work for an office or work location located in Vermont. Vermont employers must therefore include the good faith expectation of the minimum and maximum annual salary or hourly wage range for all positions for which they are hiring, including ones open to internal or external candidates and ones into which current employees may be transferred or promoted. There are special rules for commissioned and tipped jobs.
- Massachusetts: Beginning October 29, 2025, the “Massachusetts Act Relative to Salary Range Transparency” requires employers with 25 or more employees in Massachusetts to (1) disclose the pay range for a “particular and specific employment position” in the job posting, and (2) provide the pay range for a “particular and specific employment position” to an employee who is offered a promotion or transfer to such position, and (3) upon request, provide the pay range for a “particular and specific employment position” to an employee holding that position or an applicant for the position.
- As a reminder: Pay transparency laws also went into effect on January 1, 2025 affecting employers in Illinois and Minnesota.
Biometric Data Collection
- Colorado: Beginning July 1, 2025, the Colorado Privacy Act will require employers to obtain consent from employees or applicants before collecting or processing their biometric data. Biometric identifiers include, among other things, fingerprints, voiceprints, eye retina or iris scans or records, facial maps, facial geometry or facial templates, or “other unique biological, physical, or behavioral patterns or characteristics,” but do not include digital or physical photographs or audio or voice recordings or related data unless used for identification purposes.
Restrictive Covenants
- Wyoming: With the introduction of Wyo. Stat. § 1-23-108, Wyoming has banned most non-compete agreements signed on or after July 1, 2025, with several key exceptions. Although the majority of new non-compete covenants will be unenforceable, the state statute permits employers to continue using non-compete agreements with “executive and management personnel” and their professional staff, phrases that are undefined by the law. Noncompetes also remain valid in the sale-of-business context and when necessary to protect trade secrets. Employers may also require employees to repay training, education, or relocation costs if they leave within four years of employment, but on a graduated schedule: up to 100% if employment lasts fewer than two years; up to 66% for employment lasting between two and three years; and up to 33% for employment between three and four years. Non-compete agreements with physicians are prohibited outright. Agreements signed before July 1, 2025 are not affected by the law, so employers should consider their options before the law takes effect.