Paid Sick Leave: Latest Small Business Compliance Deadline

Connecticut public and private sector employers with 11-24 employees must comply with the state’s expanded paid sick leave statutes by Jan. 1, 2026. 

Whether you will be subject to this law for the first time, or need to update your policies to comply with it, the law requires that employers provide up to 40 hours of paid sick leave in a year.

It is distinct from the Connecticut’s Family and Medical Leave Act and paid leave laws, which generally allow up to 12 weeks of leave for specified reasons.

Connecticut’s Paid Sick Leave Law sets forth detailed rules regarding accrual, usage, and carryover of sick leave. Steps for compliance include updating sick leave or PTO policies as needed and posting workplace notices.

Notably, even employers with generous amounts of sick leave available may run afoul of the law if they are not attentive to other details of the law, such as the inability to require advance notice of a callout or to require documentation to support the leave.

Employee Counts

Employers with 25 or more employees were required to provide paid sick leave from Jan. 1, 2025.

From Jan. 1, 2027, the law will apply to employers with at least one employee in the state. (Take note, employers of a family nanny, housekeeper, or personal care attendant!)

From Jan. 1, 2027, the law will apply to employers with at least one employee in the state.

Employee count will be determined by the employer’s payroll for the week containing Jan. 1 each year (this previously was Oct. 1).

Further, manufacturers and certain nonprofits were previously excluded from coverage; those exclusions are removed under the new legislation.  

The only stated exclusions now are employers participating in certain construction multiemployer health plans and self-employed individuals.

Covered Employees

Previously, the CPSLL applied only to “service workers,” certain categories of hourly employees.  

Now, virtually all employees are covered, regardless of function and whether they are exempt or non-exempt.  

Seasonal employees, defined as employees working fewer than 120 days per year, are excluded.  

Day or temporary workers used to be excluded from coverage; it appears that their coverage will now be determined by whether they work fewer than 120 days per year and therefore meet the definition of a “seasonal employee.”

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About the author: Rebecca Goldberg is a partner in Berchem Moses PC’s Milford office. She works with human resources professionals and business managers to counsel them through the most challenging workplace situations, from harassment complaints to concerns about an employee’s mental or physical health. Goldberg frequently publishes articles to help employers keep up with new Connecticut and federal laws, providing timely practical guidance.