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Connecticut Paid Sick Leave Law Changes Effective January 1, 2025

Starting January 1, 2025, significant changes to the Connecticut Paid Sick Leave Law take effect under CT HB 5005. These amendments aim to expand employee benefits and provide greater flexibility in using paid sick leave. Employers must understand these changes and take the necessary steps to ensure compliance. Here’s an overview of the amended law and recommended actions to prepare for the changes. 

Key Changes to Connecticut Paid Sick Leave Law 

Expanded Coverage 

  • The updated law is expanded to cover all employers (not just those with service workers), except those participating in a multiemployer plan arrangement. 
  • The updated law expands the categories of employees eligible for paid sick leave, regardless of exempt or non-exempt status, except for seasonal employees who work 120 days or less a year. 
  • It reduces the threshold for employer coverage from 50 to 25 employees on January 1, 2025, and will apply to employers with 11 or more employees in the state starting on January 1, 2026, and employers with one or more employees in the state starting on January 1, 2027. 

Qualifying Reasons for Leave 

  • The law broadens the reasons for which employees can use paid sick leave, including caring for a family member with a health condition and addressing needs related to domestic violence or sexual assault. 
  • It also allows employees to use paid sick leave for preventive medical care and mental health care. 

Changes to the Definition of Family Member 

  • The definition of “child” now includes an individual to whom the employee stood in loco parentis when the individual was a child. 
  • The definition of “spouse” has been expanded to include registered domestic partners, in addition to legal marriage. 
  • “Family member” will include a spouse, sibling, child, grandparent, grandchild, or parent of an employee or an individual related to the employee by blood or affinity whose close association the employee shows to be equivalent to those family relationships. 

Waiting Period 

  • The amendments remove the 680 hours of employment and 10 or more hours worked per week standards and establish a waiting period of 120 calendar days of employment. 

Accrual and Usage: 

  • Employees will accrue paid sick leave at a rate of one hour for every 30 hours worked (previously one hour for every 40 hours worked), starting from their first day of employment. 
  • The amendments also continue to permit the frontloading of paid sick leave but now explicitly provide that those who frontload are not required to comply with the carryover provisions of the law. 

Notice and Documentation 

  • The amendments remove the seven (7) day notice requirements. 
  • The amendments specifically state that employers can no longer require documentation to establish that leave is being taken for a covered purpose. 
  • The amendments add a requirement to provide written notice (in addition to the poster) to each employee no later than January 1, 2025, or at the time of hire, whichever is later

Notably, employers can use a non-sick paid time off policy (i.e., PTO, vacation, personal time, etc.) for compliance with the Connecticut Paid Sick Leave law and do not need to provide their eligible workers additional leave if that time can be used under the same terms and conditions as outlined in the law. 

Next Steps 

Employers must take proactive steps to update their policies, systems, and practices to comply with the new requirements. To ensure compliance with the updated Connecticut Paid Sick Leave Law, employers should take the following steps: 

  • Review and Update Policies – Update your company’s sick leave policies to comply with the new requirements. Ensure that the policy clearly outlines the accrual rates, eligible uses, carryover provisions, and documentation requirements. 
  • Update Payroll and Recordkeeping Systems – Adjust your payroll systems to accurately track the accrual and usage of paid sick leave. Implement a robust record-keeping system to maintain accurate records of employees’ sick leave balances. 
  • Train HR and Management Staff – Provide training for HR personnel and management staff on the law’s new/updated requirements. Ensure they understand the changes and can effectively communicate them to employees. 
  • Communicate with Employees – Inform employees about the changes to the paid sick leave policy through written communication, staff meetings, and updates to the employee handbook. Ensure that all employees, including new hires, understand their rights and responsibilities under the law. 
  • Monitor Compliance – Regularly review your sick leave policies and practices to ensure ongoing compliance with the updated law. Conduct periodic audits to identify and address any issues promptly. 
  • Seek Legal and HR Guidance – Consult with legal experts and HR professionals to ensure full compliance with the updated law. This may include specific advice and help to address any questions or concerns regarding implementing the changes. 

HR Works, headquartered in Upstate New York, is a human resource management outsourcing and consulting firm serving clients throughout the United States for over thirty years. HR Works provides scalable strategic human resource management and consulting services, including: affirmative action programs; benefits administration outsourcing; HRIS self-service technology; full-time, part-time and interim on-site HR managers; HR audits; legally reviewed employee handbooks and supervisor manuals; talent management and recruiting services; and training of managers and HR professionals.