Connecticut: Major Changes to Paid Sick Leave Law Coming January 1, 2025

By John S. Gannon - Skoler Abbott P.C.

December 31, 2024

The New Year often brings new changes to employment laws.  That certainly is the case in Connecticut.  Effective January 1, 2025, almost all employers with 25 or more employees will need to provide paid sick leave to their workers.  Previously, the CT Paid Sick Leave Law only required eligible service workers to accrue sick leave at a rate of 1 hour of paid sick leave for every 40 hours worked, and the law only applied to employers with 50 or more employees.  Plus, many businesses were excluded under the old version of the law, including most manufacturing and non-profit employers.  These businesses are no longer exempt.  In fact, as of January 1, the only employers who will be exempt from the paid sick leave law are: (1) employers that participate in a multi-employer health plan pursuant to a collective bargaining agreement with a construction union; and (2) self-employed individuals.  In addition, the accrual rate will now be 1 hour of paid sick leave for every 30 hours worked, up to a maximum of 40 hours per year.  All employees of covered employers are entitled to accrue and use paid sick time, with the limited exception of “seasonal employees” who work 120 or fewer days in a year.

What Else Is Changing?

The new CT Paid Sick Leave Law not only increases the number of eligible employees (and changes the accrual rate), but also expands the definition of “family members.”  As many readers are likely aware, the CT Paid Sick Leave Law allows employees to take paid sick time to care for family members who are sick. The current version of the law defines “family members” as an employee’s spouse or minor child.  Effective January 1, “family members” will also include siblings, grandchildren, grandparents, domestic partners, and even “any individual related to the employee by blood or affinity whose close association the employee shows to be equivalent to those family relationships.”  Furthermore, employees will be able to use paid sick leave for new reasons, including:  (1) the closure of the employee’s workplace or a family member’s school or place of care due to a public health emergency; and/or (2) a determination that the employee or the employee’s family member poses a risk to the health of others due to their exposure to a communicable disease.

Record Retention

Currently, employers covered by the CT Paid Sick Leave Law have no formal recordkeeping obligations.  That will also change on January 1, as the new state sick leave law requires covered employers to retain sick time records for a period of three years.  The records must include: (1) the number of hours worked by each employee during the calendar year; (2) the number of hours of paid sick time accrued or provided to each employee; and (3) the number of hours used by the employee during the calendar year.

Employee Notice

As with most laws granting new rights to employees, the new CT Paid Sick Leave Law requires covered employers to post a notice in English and Spanish in a conspicuous place accessible to employees.  The new notices can be found here.  Covered employers must also separately provide written notice to employees by January 1, 2025, or at the time or hire (whichever is later) detailing their rights to paid sick time.  The state’s sample written notice can be found here.

What’s Next?

Employers that are covered by the new CT Paid Sick Leave Law need to review and (if necessary) revise Handbooks and other policies related to sick time to ensure compliance with the new law.  They also need to be sure they comply with the new employee notice and record retention requirements.

Finally, employers with less than 25 employees need to be aware that effective January 1, 2026, the  CT Paid Sick Leave Law will apply to businesses with 11 or more employees.  And, effective January 1, 2027, the sick time law will apply to all employers with 1 or more employees.

 If you have any questions about complying with the new CT Paid Sick Leave Law, or your organization’s sick time practices in general, consider contacting experienced labor and employment counsel for guidance.

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