In this month’s update, we highlight significant employment law changes and practical compliance insights to keep your business compliant, minimize risk, and empower a productive workforce. Need a customized, legally compliant employee handbook? Visit our Handbook page to build yours in just a few clicks.
HR & Legal Updates
Federal
- On January 5, the DOL published an opinion letter clarifying that employees may use their FMLA leave not only for the time spent in medical appointments, but also for the time spent traveling to and from medical appointments for their own serious health condition, or that of a qualifying family member. The opinion also stated that any medical certification required by the employer does not need to address travel time to be complete and sufficient under the FMLA.
- By February 1, employers with 11 or more employees that are not exempt from OSHA record keeping requirements must post the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses) for the previous calendar year. The summary must be posted in a conspicuous location at each worksite where employee notices are customarily displayed and remain posted through April 30.
- By February 2, employers must provide Form W-2 to each employee and file copies with the Internal Revenue Service (IRS). Form W-2 reports an employee’s wages and tax withholdings for the previous calendar year. Employers must also furnish Form 1099 (as applicable) to independent contractors or freelance workers who were paid $600 or more during the prior tax year.
- By February 2, employers must file Form W-3 (Transmittal of Wage and Tax Statements) with the Social Security Administration (SSA). Form W-3 summarizes all Forms W-2 issued by the employer for the previous calendar year and is used to transmit those wage and tax statements to the SSA.
- By February 2, employers must file Form 940 and pay any Federal Unemployment Tax Act (FUTA) taxes due for the prior calendar year. Employers that deposited all FUTA taxes on time may delay filing Form 940 until February 10, 2026.
- By February 2, employers must file Form 1099-NEC (Nonemployee Compensation) with the Internal Revenue Service (IRS) and furnish copies to recipients. Form 1099-NEC is required for each nonemployee individual or business paid $600 or more during the prior calendar year. The form may also be used to report direct sales of $5,000 or more of consumer products for resale, including buy-sell arrangements, deposit commissions, or similar transactions.
- By March 1, employers or plan administrators must file Form M-1 with the Employee Benefits Security Administration (EBSA) if they operate a multiple employer welfare arrangement (MEWA) that provides medical benefits. Form M-1 is an annual filing used to report information about the MEWA’s structure and compliance with federal requirements.
- By March 2, employers that physically file Affordable Care Act (ACA) information returns must submit Form 1094-B or Form 1094-C to the Internal Revenue Service (IRS), as applicable. Employers with fewer than 50 full-time equivalent (FTE) employees file Form 1094-B. Employers with 50 or more FTEs file Form 1094-C. Form 1094 serves as a transmittal and summary of all Forms 1095 filed for the prior calendar year. Employers that file electronically must submit Form 1094 by March 31.
- By March 2, employers that offer employee health benefit plans, such as group health insurance or health reimbursement arrangements (HRAs), must file Form 1094-B or Form 1094-C with the Internal Revenue Service (IRS), as applicable. Employers with fewer than 50 full-time equivalent (FTE) employees file Form 1094-B. Employers with 50 or more FTEs file Form 1094-C. Form 1094 serves as a summary and transmittal of all Forms 1095 filed for the prior calendar year.
- By April 15, employers and group health plan sponsors must file Form 8928 to self-report certain compliance failures related to the administration of their health plans.
- Form 8928 is used to report failures including, but not limited to:
- Failing to provide the required level of coverage for pediatric vaccines under Section 2713 of the Public Health Service Act
- Failing to comply with COBRA administration requirements
- Failing to meet portability, access, renewability, or market reform requirements
- Failing to make comparable Archer medical savings account (MSA) contributions
- Failing to make comparable health savings account (HSA) contributions
- By May 1, employers with calendar-year plans subject to the Employee Retirement Income Security Act (ERISA)must distribute a Summary Plan Description (SPD) to plan participants. For plans with an effective date of January 1, the SPD must be provided within 120 days after the plan is established. If the employer makes non-material changes to the SPD that do not affect participants’ coverage, an updated SPD may be distributed within 210 days after the end of the plan year in which the changes took effect.
- By June 1, insurance carriers and employer-sponsored health plans must submit Prescription Drug Data Collection (RxDC) reporting for 2025 calendar year plans. RxDC reporting requires the submission of information regarding prescription drug costs and overall health care spending. For fully insured plans, the insurance carrier typically completes the RxDC filing. Employers sponsoring self-insured or level-funded plans are responsible for submitting the report or coordinating filing through a third-party administrator (TPA).
- By July 31, organizations with calendar-year employee benefit plans subject to ERISA must file Form 5500. Form 5500 is an annual filing used to report information about an organization’s retirement and welfare benefit plans. This requirement also applies to employers offering an Individual Coverage Health Reimbursement Arrangement (ICHRA) with 100 or more plan participants. The specific version of Form 5500 required depends on the type of organization and the benefits offered. Employers may request a one-time filing extension by submitting Form 5558.
- By September 30, organizations with calendar-year employee benefit plans subject to ERISA that file Form 5500 must distribute a Summary Annual Report (SAR) to plan participants. The SAR provides a summary of the information reported on Form 5500 and must be delivered within nine months after the end of the plan year.
- By October 2, employers that choose to follow federal guidance for advance notice must provide a 90-day notice to employees regarding the offer of a Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) or an Individual Coverage Health Reimbursement Arrangement (ICHRA). The notice should inform employees that the QSEHRA or ICHRA will be offered effective January 1, 2027.
- By December 31, employers with calendar-year benefit plans should complete nondiscrimination testing (NDT) for applicable health and welfare benefit plans. While testing is generally completed by the end of the plan year, employers are encouraged to conduct testing earlier to allow time to identify and correct any compliance issues.Benefit plans subject to nondiscrimination testing may include retirement plans, flexible spending accounts (FSAs), health savings accounts (HSAs), and health reimbursement arrangements (HRAs). Nondiscrimination testing is used to ensure that benefit plans do not disproportionately favor highly compensated employees.
Arizona
- Flagstaff: On January 1, 2026, the minimum wage in Flagstaff, AZ will rise to $18.35.
- Flagstaff: As of January 1, 2026, the use of a tip credit is eliminated under the Flagstaff Minimum Wage Ordinance. Employers must pay tipped employees at least the full Flagstaff minimum wage before tips. This means that employers in Flagstaff must pay tipped employees the full minimum wage of $18.35 per hour, regardless of the amount of tips received.
- Tucson: On January 1, 2026, the minimum wage in Tucson, AZ will rise to $15.45.
California
- The withholding rate for California State Disability Insurance (which funds the state’s paid family and medical leave program) will increase from 1.2% to 1.3% in 2026.
- Beginning January 1, 2026, under AB 692, California employers will no longer be allowed to use Training Repayment Agreement Provisions (TRAPs), also known as “stay-or-pay” agreements. TRAPs are agreements or provisions in employment contracts that require employees to pay certain penalties, fees, or costs if they leave their job before a set time, with limited exceptions. Specifically, the law prohibits any agreement or provision that:
- Requires the worker to pay an employer, training provider, or debt collector for a debt if the worker’s employment or work relationship with a specific employer terminates;
- Authorizes the employer, training provider, or debt collector to resume or initiate collection of or end forbearance on a debt if the worker’s employment or work relationship with a specific employer terminates; or
- Imposes any penalty, fee, or cost on a worker if the worker’s employment or work relationship with a specific employer terminates.
- Some types of loan or tuition repayment contracts are exempt from this prohibition.
- The California Civil Rights Department recently published preliminary versions of pay data reporting templates for Reporting Year 2025. The 2025 preliminary templates are a simplified version of the official templates and are intended to help filers become familiar with the expected format and data fields for Reporting Year 2025. A companion FAQ document provides answers to frequently asked questions on the templates, including three newly proposed columns to collect information on employee exemption status, employment type, and weeks worked. These templates are subject to change and are intended for planning purposes only; they should not be filed with the state. As a reminder, the employer filing period is expected to run from early February until May 13, 2026.
- On October 12, 2025, Governor Newsom signed Senate Bill (SB) 294, which requires employers in California to provide a stand-alone written notice of worker rights to each new employee when hired, and annually to all current employees. In response, the California Labor Commissioner published this model notice for employers to provide to employees. Employers have until February 1, 2026, to provide this notice to employees. The notice must be provided in a language the employer normally uses to communicate with employees about business matters that employees understand. At present, the Labor Commissioner’s template is available in English and Spanish.
- The Department of Labor Standards Enforcement released a revised Healthy Workplaces/Healthy Families Act: California Paid Sick Leave poster that reflects changes to sick leave law concerning the use sick leave by employees or their family members who are victims of domestic or other types of violence.
- California: On January 1, 2026, the hourly minimum wage will increase to $16.90 from $16.50.
- Belmont: On January 1, 2026, the minimum wage in Belmont, CA will rise to $18.95 per hour.
- Burlingame: On January 1, 2026, the minimum wage in Burlingame, CA will rise to $17.86 per hour.
- Cupertino: On January 1, 2026, the minimum wage in Cupertino, CA will rise to $18.70 per hour.
- Daly City: On January 1, 2026, the minimum wage in Daly City, CA will rise to $17.50 per hour.
- East Palo Alto: On January 1, 2026, the minimum wage in East Palo Alto, CA will rise to $17.90 per hour.
- El Cerrito: On January 1, 2026, the minimum wage in El Cerrito, CA will rise to $18.82 per hour.
- Foster City: On January 1, 2026, the minimum wage in Foster City, CA will rise to $17.85 per hour.
- Half Moon Bay: On January 1, 2026, the minimum wage in Half Moon Bay, CA will rise to $17.91 per hour.
- Hayward: On January 1, 2026, the minimum wage in Hayward, CA will rise to $17.79 per hour for employers with more than 25 employees and $16.90 for employers with 25 or fewer employees.
- Los Altos: On January 1, 2026, the minimum wage in Los Altos, CA will rise to $18.70 per hour.
- Menlo Park: On January 1, 2026, the minimum wage in Menlo Park, CA will rise to $17.55 per hour.
- Mountain View: On January 1, 2026, the minimum wage in Mountain View, CA will rise to $19.70 per hour.
- Novato: On January 1, 2026, the minimum wage in Novato, CA will rise to $16.90 per hour for employers with 25 or fewer employees, $17.46 per hour for employers with 26-99 employees, and $17.73 for employers with 100 or more employees.
- Palo Alto: On January 1, 2026, the minimum wage in Palo Alto, CA will rise to $18.70 per hour.
- Petaluma: On January 1, 2026, the minimum wage in Petaluma, CA will rise to $18.31 per hour.
- Redwood City: On January 1, 2026, the minimum wage in Redwood City, CA will rise to $18.65 per hour.
- Richmond: On January 1, 2026, the minimum wage in Richmond, CA will rise to $19.18 per hour for employers who pay less than $1.50 per hour towards medical benefits, and $17.68 per hour for employers who pay at least $1.50 per hour towards medical benefits.
- San Carlos: On January 1, 2026, the minimum wage in San Carlos, CA will rise to $17.75 per hour.
- San Diego: On January 1, 2026, the minimum wage in San Diego, CA will rise to $17.75 per hour.
- San Jose: On January 1, 2026, the minimum wage in San Jose, CA will rise to $18.45 per hour.
- San Mateo: On January 1, 2026, the minimum wage in San Mateo, CA will rise to $18.60 per hour.
- San Mateo County: On January 1, 2026, the minimum wage in the unincorporated areas of San Mateo County, CA will rise to $17.95 per hour.
- Santa Clara: On January 1, 2026, the minimum wage in Santa Clara, CA will rise to $18.70 per hour.
- Santa Rosa: On January 1, 2026, the minimum wage in Santa Rosa, CA will rise to $18.21 per hour.
- Sonoma: On January 1, 2026, the minimum wage in Sonoma, CA will rise to $18.47/hour for large employers (26 or more employees) and $17.38/hour for small employers (25 or fewer employees).
- South San Francisco: On January 1, 2026, the minimum wage in South San Francisco, CA will rise to $18.15 per hour.
- Sunnyvale: On January 1, 2026, the minimum wage in Sunnyvale, CA will rise to $19.50 per hour.
- West Hollywood: On January 1, 2026, the minimum wage in West Hollywood, CA will rise to $20.25 per hour for non-hotel workers.
Colorado
- Colorado published to official 2026 COMPS Order. This order must be posted in a visible place where employees can see it. It must also be included in employee handbooks. This new Order takes effect January 1, 2026. The state has not yet released the official poster, but employers can view the changes through link included here. The proposed Order can be found here.
- On December 8, 2025, the Department of Labor and Employment adopted a corrected version of COMPS Order #40 though no substantive corrections were made. The most recent version of COMPS Order #40, which will be formally published in the Colorado Register on December 25th, must be used by employers, including having a copy in their company handbook, manual, or policies, beginning February 1, 2026.
- For 2026, the contribution rate to the state’s paid family and medical leave program will decrease from .9% of wages to .88% of wages.
Connecticut
- Then CT Paid Leave maximum benefit rate is now $1,016.40, which is capped at 60 times the state minimum wage.
Delaware
- Delaware’s paid family and medical leave program is set to take effect on January 1, 2026. The state has just made several important amendments that employers need to be aware of:
- Previously, employers were able to select the 12-month application period using one of the four methods that are also offered under the FMLA. Under the new amendments, all employers must use the 12-month period measured forward from when the employee first takes leave under the the law.
- Employees are eligible for paid family leave if they “primarily” work in Delaware. The amendments clarify that this means the employee must earn at least 60% of their wages physically in Delaware.
- Employers that offer paid leave benefits voluntarily beyond what is required by the act are not allowed to require employees to contribute towards payments for those additional benefits. Employers must pay for those additional benefits themselves.
- Employers may not require employees to use their PTO before accessing paid family benefits. But they can agree with an employee to use their PTO to supplement their paid leave benefits up to 100% of wages. Any agreement must be in writing and signed.
District of Columbia
- Under amendments to the DC Fiscal Year 2026 Budget, employers must include all the sources of an employee’s compensation on their pay stubs, including bonuses, commissions on sales, service charges, as well as any other sources.
Illinois
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- Last week, Governor Pritzker signed S 2339 amending the state’s Right to Privacy in the Workplace Act. Under the amended law, employers may not take any adverse action against employees based purely on notice from any party not responsible for enforcing immigration law, such as the SSA or IRS, that there is a discrepancy with a tax ID number or other identifying documents.
- Employers must provide notice to the affected employee within 5 business days and allow the employee to contest the mismatch within the time period as required by federal law. If possible, this notice should be delivered in person. If it’s not possible to deliver it in person, the notice must be delivered to the employee by both mail and email (if known), and the employee’s authorized representative must be notified.
- Last week, Governor Pritzker signed S 2339 amending the state’s Right to Privacy in the Workplace Act. Under the amended law, employers may not take any adverse action against employees based purely on notice from any party not responsible for enforcing immigration law, such as the SSA or IRS, that there is a discrepancy with a tax ID number or other identifying documents.
- Employers can face penalties up to $5,000 for repeat violations. These requirements went into effect immediately upon signature, on December 12, 2025.
- On December 9, 2025, Governor Pritzker signed HB 1312 amending the Illinois Whistleblower Act to prohibit employers from retaliating against an employee for disclosing or threatening to disclose in good faith any violation of the Illinois or US. Constitution during civil immigration enforcement or violations of the Illinois Bivens Act. These amends took effect upon becoming law.
Louisiana
- Louisiana requires employers to provide Form 77 to the state and the separating employee detailing the reasons for the separation. Employers now have 10 days (an increase from the prior requirement of 3 days) to provide separated employees and the state with the separation form. Additionally, the law specifies that the form needs to be electronically transmitted to Louisiana Works, removing the options for mail or delivery.
Maine
- Maine prohibits non-competes with employees who earn less than 400% of the federal poverty level. The Department of Health and Human Services has released updated federal poverty guidelines, which places Maine’s new non-compete income threshold at $63,840 per year.
- Portland: On January 1, 2026, the minimum wage in Portland, ME will rise to $16.75 per hour for hourly employees and $8.38 for service employees.
- Rockland: On January 1, 2026, the minimum wage in Rockland, ME will rise to $16 per hour.
Maryland
- Howard County: On January 1, 2026, the minimum wage in Howard County, MD will rise to $15.50 per hour for employers with 14 or fewer employees. Employers with 15 or more employees must continue paying the same minimum wage of $16 per hour.
- Howard County: On July 1, 2026, the minimum wage in Howard County, MD will rise to $16 per hour for all employers.
Massachusetts
- Revere: On October 27, 2025, the Revere City Council adopted an ordinance amending existing law, which prohibits employers from committing wage theft by not making a timely or complete payment of wages including earned overtime and allows for anonymous reporting of wage theft. The amended Ordinance also permits the City to revoke licenses, stop tax incentives, or suspend contracts with businesses that commit wage theft. The amended Ordinance took immediate effect.
Minnesota
- Under Minnesota’s new paid leave law, employers are now required to include any amount deducted by the employer under the paid leave law in employee pay stubs.
- Minneapolis: On January 1, 2026, the minimum wage in Minneapolis, MN will rise to $16.37 per hour.
- Saint Paul: On January 1, 2026, the minimum wage in Saint Paul, MN will rise to $13.25 per hour for employers with fewer than 6 employees, $15 per hour for employers with 6-100 employees, and $16.37 per hour for employers with more than 100 employees.
- Saint Paul: On July 1, 2026, the minimum wage in Saint Paul, MN will rise to $14.25 per hour for employers with fewer than 6 employees and $16.37 per hour for employers with 6 or more employees.
- Minnesota recently released new versions of the state’s Minimum Wage and Paid Leave posters.
New Hampshire
- Under New Hampshire’s parental leave law, employers with 20 or more employees must provide up to 25 hours of leave for employees to attend their own medical appointments related to pregnancy, childbirth, or postpartum care, or to attend their child’s pediatric medical appointments within 1 year of the child’s birth or adoption.
New Jersey
- For 2026, the employee contribution rate to the state’s paid family and medical leave program will decrease from .33% of taxable wages to .19% of taxable wages. Click here for more information from the state.
- On December 15, 2025, New Jersey’s Division on Civil Rights adopted new rules on disparate impact employment discrimination. The final rules are generally similar to the disparate impact discrimination protections provided under federal law prior to the current administration, but they also clarify that the use of automated employment decision tools is subject to the same disparate impact protections as other processes used to make employment decisions, including those related to recruiting, interviewing, and the terms and conditions of employment. The final rules also confirm that automated employment decision tools that screen out applicants must include a mechanism for applicants to request reasonable accommodations.
New Mexico
- Las Cruces: On January 1, 2026, the minimum wage in Las Cruces, NM will rise to $13.01 per hour.
New York
- For 2026, employees will contribute 0.432 % of their gross wages per pay period to the state’s paid family and medical leave program, with a maximum annual contribution of $411.91.
- On December 5, 2025, Governor Hochul signed SB 3398 clarifying that it is unlawful to discriminate or retaliate against individuals who requested a reasonable accommodation. The legislation notes that the amendments just clarify existing law and don’t mean that current law doesn’t already prohibit retaliation for requesting a reasonable accommodation. The amendments took effect immediately when signed.
- On December 19, 2025, Governor Hochul signed a law clarifying the standard for when an employment practice has a discriminatory effect and confirming that a practice may be unlawful due to its discriminatory effect even when it is not motivated by a discriminatory intent. In particular, the legislation amends existing law to clarify that a practice has a discriminatory impact where it actually or predictably results in a disparate impact on a group because of their membership in a protected class. Exceptions exist for practices that have a legally sufficient justification due to being job-related and consistent with business necessity which cannot be served by another practice with a less discriminatory effect. The legislation took immediate effect.
- Governor Hochul signed a law extending paid family and medical leave benefits to more workers. Covered employees who perform construction, demolition, reconstruction, excavation, rehabilitation, repairs, renovations, alterations, or improvements for multiple employers under a collective bargaining agreement are now eligible to apply for paid family and medical leave benefits if they were employed for at least 26 of the last 39 weeks. The law went into effect upon signing on December 19th, 2025.
- On December 19, 2025, Governor Hochul signed AB 584 creating the “Trapped at Work Act.” The Act prohibits employers from requiring as a condition of employment any worker or prospective worker to sign a contract that requires the worker to pay a sum of money if the worker leaves employment before the passage of a stated period of time or requires reimbursement for training provided to the worker. Nothing prohibits an employer from requiring repayment of advanced sums to the worker unless those sums were used to pay for training related to the worker’s employment with the employer or requiring the worker to pay the employer for any property it has sold or leased to the worker. Employers found to have violated this Act will be fined by the Labor Commissioner not less than $1,000 and not more than $5,000 per violation. Workers or prospective workers who were required to execute an employment promissory note can bring an action against the employer to recover actual damages or $5,000, whichever is greater, injunctive relief, reasonable costs, and attorney fees. The Act took effect immediately upon the Governor’s signature.
- On December 19, 2025, Governor Hochul signed Senate Bill 3072 which prohibits employers from requesting or using the consumer credit history of an applicant or employee to make employment decisions. The legislation establishes limited circumstances where it would be acceptable to consider an applicant or employee’s credit history, such as for employees in positions that require security clearance under federal or state law. The legislation takes effect 120 days after being signed into law, on April 18, 2026.
- On December 12, 2025, Governor Hochul signed Senate Bill S5294-B, requiring all general hospitals and nursing homes in New York to implement comprehensive workplace violence prevention programs. The law is designed to enhance safety and reduce injuries, deaths, and violent incidents affecting healthcare workers, patients, residents, and visitors. Starting January 1, 2027, hospitals and nursing homes must complete an annual safety and security assessment and develop written plans that include engineering controls, security measures, staff training, incident reporting, and ongoing employee involvement. Nursing homes may satisfy state requirements through compliance with federal Centers for Medicare & Medicaid Services (CMS) regulations if their plans address workplace violence. Additionally, hospitals in jurisdictions with over one million residents must maintain at least one off-duty law enforcement officer or trained security professional in emergency departments at all times. Smaller hospitals face similar requirements, with exceptions for critical access, sole community, and rural emergency hospitals, though these organizations may be required to comply if violence rates rise. These security measures, combined with assessment and written plan mandates, establish a framework to reduce workplace violence and strengthen accountability in healthcare settings.
- Governor Hochul signed Assembly Bill A2725 on December 12, 2025, requiring New York employers who are federally mandated to maintain workplace first aid supplies to include an opioid antagonist, such as naloxone, in those kits. The law applies to private-sector employers across all industries, excluding government agencies, and takes effect June 10, 2026. The Department of Labor will issue regulations specifying quantity requirements and training standards to ensure proper storage and administration.
- New York City: In October, 2025, the NYC City Council passed new pay data reporting requirements, but they were vetoed by the Mayor on November 7. However, on December 4, that veto was overridden by the City Council, enacting those new requirements immediately. Employers still have time before they need to take any action, since the law requires that the Mayor appoint an agency to manage these pay data reports within a year of the enactment of the law. After that, the agency will have 1 year to publish a standardized form for employers to use to submit their reports. Finally, all covered employers will be required to begin submitting their annual pay data reports within a year of that publication. That means pay data reporting could be required as early as 2026 or as late as 2028, depending on how quickly the Mayor and the respective agency act. When the time comes to submit reports, only employers with 200 or more employees working in NYC will be required to submit them. The content of these reports is still unclear but we will provide legal updates with more information as it happens.
Ohio
- Governor DeWine signed the E-Verify Workforce Integrity Act (HB 246) which requires nonresidential contractors, subcontractors, and labor brokers that provide workers in construction industry to use E-Verify to verify worker employment eligibility. Penalties under the Act for violations of this requirement include fines between $250-$25,000 for each violation depending on the section of the law violated and the pattern of occurrence. Employers can also be subject to civil action and disqualification from state contracts. This law will go into effect March 19, 2026.
- Columbus: The Columbus city council recently passed new protections for job applicants. Effective January 1, 2027, employers with 15 or more employees in the city will be required to include reasonable wage ranges on all job postings, except those for internal transfers/promotions. The “reasonableness” of a posting will be determined based on:
- The flexibility of the employer’s budget;
- The anticipated range of experience job applicants may have;
- The potential variation in the responsibilities of the position;
- The opportunities for growth in and beyond the position;
- The cost of living for the various locations in which an applicant may work; and
- Market research on comparable positions and salaries.
Pennsylvania
- On November 25, HB 439 was signed into law, expanding Pennsylvania’s protected characteristics. Beginning January 26, 2026, the Pennsylvania Human Rights Act’s definition of race will include traits historically associated with the individual’s race, including hair texture and protective hairstyles like locs, braids, twists, coils, Bantu knots, afros, extensions, etc. The amendments to the Human Rights Act also clarify that the term “religious creed” includes head coverings and hairstyles historically associated with religious creeds. Employers may still prohibit certain hairstyles or head coverings in the workplace if they are prohibited for a bona fide workplace health and safety reason.
- Pennsylvania requires employers with 50 or more full-time employees to display a veteran’s benefits and services poster.
- Philadelphia: On December 3, 2025, Mayor Parker signed a bill that now makes it unlawful for employers to discriminate against employees on the basis of menstruation, perimenopause, and menopause. The ordinance goes into effect on January 1, 2027.
- Pittsburgh: On November 12, 2025,Mayor Gainey signed Ordinance 2025-2359 which was passed by the Pittsburgh City Council two days prior. The ordinance amends the antidiscrimination provisions of the city’s code. The definitions of discriminate or discrimination were amended to include any difference in treatment based on an actual or perceived protected class or protected activity. This includes any act which results in unequal treatment or segregation of an individual or group of individuals, or the use of facially neutral policies or practices that have an adverse or disparate impact on people of a protected class. It defines perceived protected class to be when a person is believed to have a set of identities or traits that are protected by law against discrimination, even if that belief is incorrect. Disparate impact is defined as demonstration that a facially neutral policy or practice of a covered entity, or a group of policies or practices of a covered entity, results in an adverse impact to any protected group. The ordinance went into effect immediately.
Rhode Island
- Beginning January 1, 2026, under HB 5679, all Rhode Island employers will be required to provide new employees with a singular written notice or “mini handbook” containing summary information about the employer’s commitments and policies about employee wages. The notice must include:
- The rate or rates of pay and basis thereof, including whether the employee is to be paid by the hour, shift, day, week, salary, piece, commission, or other method, and the specific application of any additional rates;
- Allowances, if any, claimed, pursuant to permitted meals and lodging;
- The employer’s policy on sick, vacation, personal leave, holidays, and hours;
- The employee’s employment status and whether the employee is exempt from minimum wage and/or overtime;
- A list of deductions that may be made from the employee’s pay;
- The number of days in the pay period, the regularly scheduled payday, and the payday on which the employee will receive the first payment of wages earned;
- The legal name of the employer and the operating name of the employer, if different from its legal name;
- The physical address of the employer’s main office or principal place of business, and its mailing address if different; and
- The telephone number of the employer.
- Employees must acknowledge and employers must keep a signed copy of the notice.
- Beginning January 1, 2026, Rhode Island requires employers to allow employees to use up to 8 weeks of leave under the Temporary Caregiver Insurance (TCI) program to participate as a bone marrow or living organ donor. This leave is a small expansion of the program which previously only allowed employees to use leave to bond with a new child or to care for a family member with a serious health condition.
- Rhode Island prohibits non-competes with employees who earn less than 250% of the federal poverty level. The Department of Health and Human Services has released updated federal poverty guidelines, which places Rhode Island’s new non-compete income threshold at $39,900 per year.
Washington
- For 2026, the premium rate for the state’s paid family and medical leave program will increase to 1.13% of an employee’s gross wages. Employers will pay 28.57% of the total premium and employees will pay 71.43%. Click here for more information from the state.
- Washington updated its pay transparency law to require employers to disclose a fixed wage amount, rather than a scale or range, if the employer is offering only a fixed wage for a position. The law went into effect on January 1, 2026.
- The Washington Department of Labor & Industries has published permanent rules that incorporate recent legal changes in the state that allow employees (1) to use sick leave for immigration proceedings and (2) to use domestic violence leave if they were the victim of a hate crime. These permanent rules became effective on January 2, 2026.
- Beginning January 1, 2026, Washington healthcare settings must develop and implement workplace violence prevention plans, in collaboration with employer and employee-elected members of a committee, to prevent and protect employees from violence at the setting.
- Bellingham: On January 1, 2026, the minimum wage in Bellingham, WA will rise to $19.13 per hour.
- Everett: On January 1, 2026, the minimum wage in Everett, WA will rise to $18.77 per hour for employers with 15-499 employees worldwide or with annual gross revenue of more than $2 million. Employers with 500 or more employees continue to have a minimum wage of $20.24 per hour, and those with fewer than 15 employees or with annual gross revenue of less than $2 million must follow the state minimum wage.
- King County: On January 1, 2026, the minimum wage in the unincorporated areas of King County, WA will rise to $18.32 per hour for employers with 15 or fewer employees and an annual gross revenue of less than $2 million, $19.82 per hour for employers with 15 or fewer employees and an annual gross revenue of $2 million or more, $19.82 for employers with 16-499 employees, and $20.82 per hour for all other employers. Employee counts are worldwide.
- Renton: On January 1, 2026, the minimum wage in Renton, WA will rise to $21.57 per hour for employers with more than 500 employees, and $20.57 per hour for employers with 15-500 employees or employers with 1-14 employees who make over $2 million of annual gross revenue in Renton. Employers who don’t fall into one of these categories must follow the state minimum wage. Employee counts are worldwide.
- SeaTac: On January 1, 2026, the minimum wage in SeaTac, WA will rise to $20.74 per hour for hospitality and transportation employees.
- Tukwila: On January 1, 2026, the minimum wage in Tukwila, WA will rise to $21.65 per hour.
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