Akamai HR Solutions | July 2026 HR & Legal Update

July 16, 2026

As we move into the second half of 2026, now is a good time for employers to review key compliance obligations, upcoming deadlines, and workplace policy updates. This month’s HR & Legal Update highlights recent employment law developments to help employers stay current, reduce risk, and plan ahead.

For more resources, including prior HR & legal updates, visit our News & Insights page.

If you are reviewing your employee handbook or policies, we can help ensure they’re up to date and compliant. Visit our Handbook page for more information. 

Federal

  • On May 28, 2026, the Department of Labor’s Wage and Hour Division announced the publication of four Opinion Letters addressing various requirements under the Fair Labor Standards Act (FLSA):
    • FLSA2026-5: Reviews whether the FLSA permits an exempt employee to perform work in a nonexempt capacity for extra compensation in the same workweek without jeopardizing the employee’s status as exempt. The Opinion Letter confirms that an employee working in an exempt role can receive extra compensation for performing extra work in a nonexempt role without jeopardizing the employee’s exemption provided their primary duties remain those that justify their exemption and, despite the additional compensation they receive for the nonexempt work, continue to be paid on a salary basis.
    • FLSA2026-6: Discusses whether an employer’s non-discretionary quarterly bonus program, based on a percentage of the employee’s total earnings during the bonus period, complies with the FLSA’s overtime pay requirements. The Opinion Letter notes that because the amount of the non discretionary bonus is based on a percentage of the employee’s total earnings during the bonus period, including overtime, no additional overtime is owed as the percentage-based bonus simultaneously paid any additional overtime compensation due as a result of the bonus.
    • FLSA2026-7: Concerns whether the time spent voluntarily traveling off-site for a meal, particularly the time spent passing through a controlled access entry and exit point, needs to be considered when determining whether the employee’s 30-minute meal period is compensable under the FLSA. The Opinion Letter confirms the time the employee spent voluntarily leaving the premises for their meal period was not compensable time as the employer allowed employees to remain on-site for purposes of taking their 30-minute uninterrupted meal period and nothing in the FLSA prohibits an employee from using their meal period for other personal matters that might require leaving the premises.
    • FLSA2026-8: Concerns which sorts of pre-shift activities are indispensable and integral to the employee’s principal job and, as such, compensable and those that are preliminary and postliminary activities that are not under the FLSA. Compensable activities that are integral and indispensable could include, but are not limited to, donning and doffing protective gear, performing equipment checks and logging into computer systems. The Opinion Letter confirms that compensable work an employer knows of and allows employees to perform is unlikely to fall within the FLSA’s de minimis doctrine and that employers should be careful about relying on the doctrine given the technological advances that have made it easier to track time worked by employees. The Opinion Letter goes on to clarify that a rounding practice that allows employees to clock in early then rounds the time to their scheduled start time is neither facially neutral or neutral in application where the policy prohibits early clock-outs as rounding early arrival times exclusively benefited the employer.
    • While opinion letters are authoritative guidance, they do not carry the same weight as statutes or regulations. State and local law may establish more stringent requirements employers need to follow.
  • On June 9, 2026, the U.S. Department of Justice’s Office of Legal Counsel issued an opinion to the EEOC concluding that the agency’s current disparate-impact guidance under Title VII is unconstitutional. Disparate-impact discrimination theory says a policy or practice can be illegal even if it’s neutral on its face and nobody intended to discriminate if it ends up affecting one group (like a race or gender) significantly more harshly than others, and the employer can’t show it’s truly necessary for the job. Basically, it looks at the outcome of a rule rather than the intent behind it. The new opinion states that employers may use facially neutral hiring and screening tools, including aptitude tests, knowledge-based tests, and criminal-background checks, where those practices are job-related and serve a valid business purpose. The opinion takes the position that disparate-impact claims should require proof that a specific practice caused the alleged disparity and that an equally effective, less-disparate alternative was available. This follows the EEOC’s September 2025 decision to stop investigating disparate-impact charges, further signaling a narrower federal enforcement approach in this area, although private Title VII claims remain available. The opinion took effect upon issuance.

Alaska

  • Alaska’s minimum wage will increase on July 1, 2026, to $14 per hour.

Arizona

  • On June 4, 2026, Governor Hobbs signed HB 2663 updating Arizona’s military leave law to expressly cover leave for active duty or training, including service with the National Guard of another state. The law takes effect on September 12th.

California

  • Alameda: Alameda’s minimum wage will increase on July 1, 2026, to $17.76 per hour.
  • Berkeley: Berkeley’s minimum wage will increase on July 1, 2026, to $19.61 per hour.
  • Emeryville: Emeryville’s minimum wage will increase on July 1, 2026, to $20.34 per hour.
  • Fremont: Fremont’s minimum wage will increase on July 1, 2026, to $18.05 per hour.
  • Los Angeles: LA’s minimum wage will increase on July 1, 2026, to $18.42 per hour for most employers. Beginning July 1, 2026, the minimum wage for hotel workers will range from $25.00-$29.25 per hour, depending on whether the employer provides health benefits, and $25 per hour for airport workers.
  • Los Angeles County: LA County’s minimum wage will increase on July 1, 2026, to $18.47 per hour.
  • Malibu: Malibu’s minimum wage will increase on July 1, 2026, to $17.91 per hour.
  • Milpitas: Milpitas’ minimum wage will increase on July 1, 2026, to $18.50 per hour.
  • Pasadena: Pasadena’s minimum wage will increase on July 1, 2026, to $18.57 per hour.
  • San Francisco: San Francisco’s minimum wage will increase on July 1, 2026, to $19.61 per hour.
  • Santa Monica: Santa Monica’s minimum wage will increase on July 1, 2026, to $18.47 per hour for most employees. The minimum wage for Santa Monica hotel workers will be $25 per hour starting July 1, 2026.
  • West Hollywood: Beginning July 1, 2026, the minimum wage for West Hollywood hotel workers will be $20.87 per hour. Minimum wage for the rest of the city remains the same.

Colorado

  • On June 1, 2026 Colorado Governor Polis signed HB26-1113 which, effective immediately, changes rules for the administration of elections and expands voting leave. Employees are now permitted to use their existing 2 hours of voting leave on any day that Voter Service and Polling Centers (VSPCs) are open, rather than only on election day. Employers should prepare for this change as early voting in Colorado is scheduled to begin on June 22, 2026, but may vary by county.
  • Colorado has passed a new law (HB 1283) which prohibits employers from demanding, confiscating, retaining, or otherwise requiring an employee or applicant to surrender their government-issued identification card. Employers are required to provide written notice to the employee of that prohibition. The notice must be either in English or the employee’s primary language, and must be acknowledged by the employee. Employers are required to keep a record of that notice an acknowledgment in their employment records.
  • In early June, Colorado passed HB 1207 which will require private employers with 100 or more employees to provide demographic workforce data in periodic reports to the Secretary of State, beginning July 1, 2027. Each covered employer will be required to provide EEO-1 data similar to what was collected in the Federal EEO-1 reporting format as it existed on March 1, 2026, even if the federal government discontinues the federal requirement to submit EEO-1 data to the EEOC. The law takes effect on August 12, 2026.

Connecticut 

  • Connecticut amended its human trafficking training law for lodging operators. Effective October 1, 2026, hotel, motel, inn, and similar lodging operators may face civil penalties for failing to provide required human trafficking training. Existing law requires lodging operators to train each employee at the time of hire on how to recognize potential victims of human trafficking and identify activities commonly associated with human trafficking. Operators must also conduct ongoing employee awareness campaigns on activities commonly associated with human trafficking. Under SB 116, signed by Governor Lamont on May 27, 2026, the Department of Consumer Protection may impose a civil penalty of $1,000 per violation. Total penalties may not exceed $5,000 per calendar year.
  • Connecticut enacted the Artificial Intelligence Responsibility and Transparency Act. The law creates new artificial intelligence and online safety requirements for subscription services, employment decision-making, social media platforms, and state government operations. For employers, the law adds disclosure requirements and employee protections related to automated employment-related decision technology. 
    • It also updates Connecticut’s anti-discrimination law to clarify that an employer’s use of automated employment-related decision technology is not a defense to a discrimination complaint. 
    • Beginning October 1, 2026, employers must state in any WARN Act notice provided to the state whether a layoff is due to the use of artificial intelligence or other technological changes.
    • Beginning October 1, 2027, developers of automated employment-related decision technology deployed in Connecticut must provide deployers with the information needed to comply with the law. Employers and other deployers must also provide written disclosures and notices to applicants and employees before making an employment decision using technology. The notice must include information such as the purpose of the technology, the nature of the employment-related decision, the name of the technology, the categories and sources of personal data analyzed or processed, and the employer or deployer’s contact information.
    • Violations of the employer-related provisions are treated as unfair or deceptive trade practices and may be enforced by the Attorney General. The law does not create a private right of action for most violations.
  • In the state of Connecticut, private employers generally must provide unpaid, job-protected leave to employees who are required to attend military reserve or national guard meetings, trainings or drills during working hours. Amendments included in HB 5406 have clarified that Army National Guard members are a part of the state’s classes of militia, which means they are now included in these employment protections. This provision of the bill goes into effect on October 1, 2026.
  • On June 4, 2026, Governor Lamont signed SB 472, a bill amending Connecticut law governing electronic monitoring of employees by employers. The law modifies the notice requirements that employers must follow before engaging in electronic monitoring – employers must give prior written notice to affected employees and post a conspicuous notice disclosing the types of monitoring and the specific locations where monitoring may occur. Employers who engage in electronic monitoring must also provide each employee hired on or after October 1, 2026, with a plain language written statement identifying activities that are prohibited and may be monitored without prior notice, before the employee begins their employment. The Labor Commissioner may levy civil penalties against employers who violate the notice requirements, with a maximum of $500 for the first offense, $1,000 for the second offense, and $3,000 for the third and each subsequent offense. This law goes into effect on October 1, 2026.

District of Columbia

  • Washington D.C.’s minimum wage will increase on July 1, 2026, to $18.40 per hour.

Florida

  • Florida amended its law on civil actions for discrimination claims. The amendments take effect July 1, 2026. Previously, a civil action had to be filed no later than one year after the Florida Commission on Human Relations issued a determination of reasonable cause. Under HB 1407, signed by Governor DeSantis on May 22, 2026, a civil action must be filed no later than one year after either the commission’s reasonable cause determination or the EEOC’s Notice of Right to Sue, whichever occurs earlier. If the commission does not issue a reasonable cause determination and the EEOC does not issue a Notice of Right to Sue within 180 days after the complaint is filed, a civil action may be filed no later than 18 months after the complaint was filed.

Hawaii

  • Hawaii amended its background check law for healthcare facilities. The amendments take effect July 1, 2026. HB 2576 updates several definitions under the law, including the definition of “direct patient access employee.” The law also adds definitions for “fingerprint-based background check” and “name-based background check.” The amendments clarify which healthcare workers must undergo a background check and what consent employees must provide to the Department of Health before the background check may be conducted.

Illinois

  • Chicago: According to the schedule in Chicago’s minimum wage ordinance, the minimum wage will increase on July 1, 2026, to $17.05 per hour.
  • Cook County: According to the schedule in Cook County’s minimum wage ordinance, the minimum wage will increase on July 1, 2026, to $15.40 per hour.

Iowa

  • On June 2, 2026, Governor Reynolds signed SB 2218 that, among other things, creates new restrictions and penalties tied to employment eligibility and false Social Security numbers. Most notably, the law prohibits an employer from hiring or continuing to employ an individual if the employer knows the individual provided a Social Security number that does not belong to that employee. The law also authorizes the Iowa Department of Workforce Development to impose a civil penalty of $10,000 per violation. For a fourth or subsequent violation, the employer must also cease operations at the location of the violation until a majority of owners and all managerial staff at that location complete compliance training developed by the Department. The law also creates related criminal exposure for individuals who falsely provide a Social Security number to obtain or retain employment and for employers who knowingly provide a fraudulent Social Security number to a potential employee for hiring purposes. The legislation took effect upon being signed.

Louisiana

  • Louisiana enacted a law addressing portable benefit accounts for independent contractors. The law takes effect August 1, 2026. HB 301, signed by Governor Landry on May 22, 2026, allows hiring parties to contribute to a portable benefit account on behalf of an independent contractor without jeopardizing the worker’s independent contractor status. A hiring party may contribute its own funds or withhold funds from an independent contractor’s pay for contributions to a portable benefit account. If funds are withheld from the contractor’s pay, the withholding must be expressly agreed to in writing by both parties, clearly and prominently stated in the agreement, voluntary, and based on the contractor’s opt-in consent. The contractor must also be able to opt out at any time.
  • The State of Louisiana has enacted job protection for living organ donors (SB 409). The law requires private employers to provide unpaid, job-protected leave to an employee who serves as a human organ donor or blood marrow donor if the employee requests a leave of absence in writing. An employer must provide leave to the employee for the duration they request, or a maximum of 30 days. Employers cannot discharge, demote, suspend, threaten, harass, or discriminate against an employee in any matter for requesting or taking a leave covered under this law. This law goes into effect on August 1, 2026.
  • On June 2, 2026, Governor Landry signed HB 622, amending the state’s criminal history record confidentiality requirements for employers that obtain employee or applicant background checks. The legislation clarifies that criminal history record information may not be released or disclosed to another person or agency absent a court order by removing prior language that allowed the information to be released with the written consent of the individual being investigated. The legislation also prohibits an employer from sending a copy of a background history check to another employer seeking referral of a potential applicant. The law takes effect on August 1, 2026.

Maine

  • Maine recently passed LD 2200, expanding non-compete protections for healthcare workers. Beginning July 29, 2026, non-competes with healthcare practitioners will be unenforceable unless they have an ownership interest in the practice. Further, non-competes that are executed with healthcare practitioners who do have an ownership interest will take effect immediately and must contain a clause recognizing an individual’s right to choose their own healthcare practitioner.

Maryland 

  • Howard County: Howard County’s minimum wage will increase on July 1, 2026, to $16 per hour for all employers.
  • Montgomery County: Montgomery County’s minimum wage will increase on July 1, 2026, to $18 per hour for employers with 51+ employees, $16.50 for employers with 11-50 employees, and $15.95 for those with 1-10 employees.

Minnesota 

  • St. Paul: St. Paul’s minimum wage will increase on July 1, 2026, to $16.37 per hour for employers with 6+ employees and $14.25 for those with 5 or fewer employees.

New Hampshire

  • New Hampshire recently passed SB 402, implementing new non-compete restrictions. Beginning July 7, 2026, non-competition agreements with physician associates will be unenforceable. This prohibition applies only to agreements signed on or after the effective date. Further, any agreements that do contain non-compete agreements that are unenforceable under this new law will only have the violative portions voided–the remaining provisions will be enforced to the extent they are otherwise in compliance with the law.

Oregon

  • Oregon’s minimum wage will increase on July 1, 2026, to $15.55 per hour.
  • Portland: Portland’s minimum wage will increase on July 1, 2026, to $16.80 per hour for employers in the Portland Metro area and $14.55 for those in nonurban counties.

Pennsylvania

  • Philadelphia: Philadelphia voters approved a ballot measure authorizing the creation of the Philadelphia Retirement Savings Program, establishing the first city administered automatic enrollment IRA framework in the United States. The program, Philly Saves, will require employers without qualified retirement plans to facilitate payroll deductions into employee Roth IRAs through a city managed system, with employer thresholds and phased implementation to be defined in rulemaking. Contributions begin July 1, 2027.

Rhode Island

  • On June 18, 2026, Governor McKee signed companion bills (H8504/S2921) which amend the state’s Fair Employment Practices law to remove language that excluded individuals employed in domestic service from the definition of “employee,” extending state anti-discrimination protections to domestic workers. As a result of the legislation, domestic workers of household employers and service providers supporting those relationships are considered to be employees covered under Rhode Island employment discrimination law. The legislation took effect upon signing.
  • On June 18, 2026, Governor McKee signed companion bills (H7364/S2504) creating the Warehouse Worker Protection Act for certain large warehouse employers. The bills (1) require covered employers to provide written quota disclosures at hire and at least two days before any new or modified quota takes effect, (2) prohibit quotas that interfere with meal and rest periods, bathroom use, or safety compliance, and (3) require employers to provide employees with their own work speed data and certain aggregated comparison data within 21 days of a request. The legislation also authorizes enforcement by the Department of Labor and Training, permits employees to seek injunctive relief and attorneys’ fees, and creates a rebuttable presumption of retaliation for adverse action taken within 90 days after an employee exercises rights under the law. The legislation takes effect on January 1, 2027.

Washington

  • Everett: Everett’s minimum wage will increase on July 1, 2026, to $19.77 for employers with 15-499 employees or gross income over $2 million revenue in Everett. The minimum wage remains at $20.77 for those with 500+ employees. Everett’s minimum wage ordinance doesn’t cover smaller employers, so they are only subject to the state minimum wage.
  • Renton: Renton’s minimum wage will increase on July 1, 2026, to $21.57 for employers with 15+ employees. Renton’s minimum wage ordinance doesn’t cover smaller employers, so they are only subject to the state minimum wage.

 

Disclaimer: The information in this HR & Legal Update is provided for general educational purposes only and does not constitute legal advice. Akamai HR Solutions, LLC is not a law firm, and no attorney–client relationship is created by your use of this content. Laws may change or apply differently to your business. For legal guidance tailored to your specific circumstances, please consult a qualified attorney.