U.S. Updates

City and State Updates

San Francisco, California

The San Francisco Paid Parental Leave Ordinance (SF PPLO) has been amended to reduce the employment tenure requirement for eligible employees from 180 days to 90 calendar days, effective September 7, 2026. To qualify, an employee must:

• Work at least 8 hours per week and perform at least 40% of their weekly work hours within San Francisco;

• Be eligible for California Paid Family Leave bonding benefits; and

• Have been employed by their current employer for at least 90 calendar days before the leave start date.

To be clear, the current 180-day employment requirement will remain in effect for all employers through December 31, 2026. Thereafter, the following transition periods apply based on number of employees:

• Beginning January 1, 2027, for employers that regularly employ 100 or more employees; and

• Beginning January 1, 2028, for employers that regularly employ 20 to 99 employees.

After the applicable transition period ends, employers must apply the new 90-day employment requirement. There are no changes to the provisions under the ordinance, but employers should make note of the expanded coverage following the transition periods and update any internal resources. You may view the amended ordinance here.

Connecticut

As a part of HB 5003 that goes into effect October 1, 2026, employers will have a new requirement to provide their employees with a written notice of their rights to accommodations under the Americans with Disabilities Act. Employers shall provide notice to:

• New employees at the start of their employment;

• Existing employees within 120 days of October 1, 2026; and

• Any employee who notifies their employer of their disability within 10 days of such notification.

Employers may comply with these provisions by placing a workplace poster at their worksite developed by the Labor Commissioner. At this time, the Connecticut Labor Commissioner has yet to provide this poster and we will provide another update once this becomes available. It is possible that the Labor Commissioner will create additional notice requirements to the ones listed above, and we will keep you informed if more information and guidance is released prior to the effective date.

HB 5003 also mandates reasonable break time for pumping or breastfeeding in addition to standard scheduled breaks.

Illinois

The Prairie State had a busy legislative session this past cycle, with three major changes for Illinois employers all coming into effect as of January 1, 2027.

• Paid Jury Duty: While employers with at least 1 Illinois employee are required to provide jury duty to any employee in the state, employers with at least 26 employees will be required to provide compensation to eligible employees serving on jury duty at their regular rate of pay. The requirement to provide pay does not apply to employers with 25 or fewer employees.

• Protections For Volunteer Emergency Responders: Employers will not be able to penalize or discipline employees, who are volunteer emergency responders, for taking leave to participate in required training. Further, employers can’t require those employees to utilize vacation time or other paid time off in order to respond to an emergency or participate in training. Employers will be able to request from employees who either respond to an emergency as a volunteer emergency worker, or are participating in training, to provide a written statement from a supervisor or acting supervisor of the volunteer emergency service to confirm the employee did indeed respond to the emergency and the time and date of said emergency.

• The Menopause Equity and Care Act: The Illinois Human Rights Act has been amended to include menopause-related symptoms and conditions as a protected status. Per the amendment, “menopause-related condition” means perimenopause, menopause, and associated medical or symptomatic conditions that include, but are not limited to, vasomotor symptoms, sleep disruption, cognitive or mood changes, and osteoporosis-related changes.

  Employers will be required to provide reasonable accommodation for employees experiencing menopause-related conditions, such as flexible scheduling or modified work hours, and a temperature or climate-adjusted workspace. Lastly, employers will be responsible to inform employees of their right to reasonable accommodation related to pregnancy and menopause-related conditions through either a workplace poster or in the employee handbook. It’s not yet available, but the Department of Public Health will develop necessary resources like guides and workplace posters and publish them on their website – we will notify you as soon as they’re available.

Maryland

We wanted to give a quick heads-up that if you were intending to apply for a private plan for Maryland’s upcoming Family and Medical Leave Insurance (MD FAMLI) program, and you wish to be exempt from contributions during the seeding period, then you will need to submit a Declaration of Intent (DOI) between September 1 through November 15, 2026. You’ll be notified if your submission is accepted within 15 days. As a reminder, private plan applications will be available in the summer of 2027.

For instructions on how to submit a DOI or for more information on private plans in general, you can read more on the MD FAMLI website. For Larkin clients interested in setting up a MD FAMLI private plan, please contact your Client Success Manager to discuss next steps. If you are not currently a Larkin client but would like further details, feel free to contact us here.

Massachusetts

Similar to what we saw earlier this year with Washington, Massachusetts is also changing the way that contributions are distributed for their Paid Family and Medical Leave (MA PFML) program. Currently for the 2026 year, the total contribution rate for employers with 25 or more covered individuals is 0.88% of eligible wages, with the employer share being 0.42% for medical contributions only, and the employee share being 0.40% between both medical and family contributions.

However, for 2027, the amendments that come from HB 5470 change this dynamic so medical benefits will be entirely funded by employee contributions, as employers will no longer be required to contribute to medical benefits. Family leave benefits will be funded by a 40/60 split between employees and employers, respectively. As a result, medical leave benefits will no longer be taxable, but family leave benefits will be.

Contributions are capped at the Social Security taxable maximum, which typically updates in October. Once this information is out and the Department of MA PFML releases further guidance on their website, we will let you know.

Minnesota

The 2027 premium rates for the Minnesota Paid Leave Law (MN PLL) program have been confirmed and, thankfully, will remain the same as the 2026 rates.

As a reminder, the premium rate will remain at 0.88% of covered wages in Minnesota, or 0.66% for small employers, split between both employers and employees. Employees will contribute up to 0.44%, regardless of employer size up to the Social Security Wage Base. Employers with more than 30 Minnesota employees are expected to contribute the remaining 0.44%, while employers with 30 or fewer employees (i.e., small employers) are expected to contribute at least 25% of the premiums (i.e., 0.22% of the total premium). As a reminder, there is a premium calculator available to help employers estimate costs under the program.

New York

The maximum weekly benefit amount for NY Paid Family Leave (NY PFL) benefits beginning January 1, 2027 will increase to $1,287.91 (from $1,228.53 in 2026). Other updates such as the required notices and contribution rates will likely be released later this year. We will continue to monitor and update our resources as details become available.

New York City

You may remember how we notified you that the city’s Earned Safe and Sick Time Act (ESSTA) amendments were enacted in February. Well, the New York City Department of Consumer and Worker Protection (DCWP) has finalized amending rules to better adopt the framework that went into effect back in February. These amendments mean there will be further changes to the ESSTA, effective July 23, 2026. While we won’t cover them all, here are the highlights:

• References to “safe and sick time” are now referred to as “protected time off”, and several examples within the rules have been updated to reflect the requirement of providing employees with both paid and unpaid protected time off.

• When an employee’s use of protected time off or paid prenatal leave results in an absence of more than 3 consecutive work days, employers may require reasonable documentation to confirm the time was protected under the law. For any use of protected time off that is not for sick time, safe time, or paid prenatal leave, documentation will be considered reasonable so long as the documentation shows the reason for the amount of time taken.

• An employer’s written protected time off and paid prenatal leave policy must address the minimum 32 hours of unpaid protected time off that is available for an employee’s use as of the first day of employment and the first day of each calendar year, as well as the carry-over policy, if applicable. As a reminder, the unpaid safe/sick time is not required to be carried over to the following calendar year.

• When an employee is absent for a protected reason and has both paid and unpaid protected time off available, the employer must provide paid protected time off to cover the absence unless the employee requests unpaid protected time off instead. Should an employee not have enough accrued paid protected time off, the employer shall instead provide unpaid protected time off to cover the absence.

There are several other minor updates regarding rehires, separation, employer records, etc., so we recommend that you consult with internal experts to ensure that you as a company are meeting your operational obligations and updating your policies, procedures, and resources, as necessary.

Puerto Rico

Puerto Rico’s Office of the Women’s Advocate released a detailed guide on breastfeeding rooms in workplace and public spaces under the Puerto Rico Lactation Code (Act 87-2025) on July 15, 2026. The new guide recommends written policies, procedures, educational responsibilities, and accommodations for remote employees and other work spaces. Below is a brief summary of the guide:

• Remote employees and those working on a hybrid schedule are entitled to the same lactation rights as those who work on site. This means employers are still responsible for providing paid lactation breaks regardless of where an employee works. During these paid lactation breaks, employers are prohibited from scheduling work related activities and requiring employees to keep communication tools (e.g., cameras, microphones, etc.) activated while expressing milk.

• Employers must also ensure compliant lactation access even when employees work at a client or contractor location. Lactation rooms provided by third party sites can be used as long as employees can reliably use them during their lactation breaks, otherwise employers must find other arrangements to accommodate their nursing employees.

• For employers in multi-tenant environments with shared facilities, they may also meet their obligations by allowing employees access to any shared lactation rooms. Employees must have timely access to use these facilities and employers should ensure the available lactation rooms remain compliant with the Act’s requirements for privacy, cleanliness, ventilation, access to electricity and water, and refrigeration.

• Beyond providing an adequate space and allowing employees breaks to pump, the guide also provides recommendations for adopting written policies, educating employees of their lactation rights, and also assigning a coordinator to oversee maintenance of rooms and spreading awareness of available resources to support employees. Although the Act provides lactation rights for nursing employees for up to 12 months, the new guide explains employers have the option of extending this duration, and if they choose to do so, should apply it consistently according to the company’s policies.

Employers should review their current policies to ensure compliance with the expanded guidance, and train their employees on the new employer obligations.

South Carolina

Governor McMaster recently signed Senate Bill 1043, enacting the Civil Air Patrol Leave Act. Effective October 1, 2026, any South Carolina employee who is a member of the official civilian auxiliary of the United States Air Force (i.e., the Civil Air Patrol) will be entitled to a minimum of 30 days per calendar year for responding to an emergency service operation, and 10 days per year for training and proficiency activities.

Because the 30 and 10 day caps are a minimum, employers have the discretion to grant additional days of leave, or to permit employees to utilize up to 5 days from one category for the purpose of the other if the desired category has an insufficient balance. Further, private employers may choose to provide paid or unpaid Civil Air Patrol Leave, and the leave should be made available in a lump sum at the start of the calendar year. Any unused time will not be carried over to the next year.

Employers may require employees to provide proof of the need for training-related leave or operation-related leave. Proof of participation may include documentation from a training provider, the operation’s leadership, or either’s designee. Employers may deny requests for this leave if the employee has been designated as an essential employee.

Employees wishing to utilize this leave should:

• Notify their employer within 30 days of accepting a job with their employer;

• Inform their employer of their intent to return to work within 8 hours of ending participation in an emergency services operation;

• Return to work within 18 hours of ending said participation, or at the start of their next scheduled workday, whichever is later; and

• Update their employer periodically on the expected duration of any absence and expected date of return due to an emergency service operation.

Note that in the first bullet point above, employees are required to notify their employer that they are a member of the Civil Air Patrol within 30 days of accepting a job with their employer – since some employees may already be hired and hold this status, the law provides that within 30 days of October 1, 2026, current members should notify their employer(s), if currently holding employment.

If your company includes South Carolina-specific leave information, consider updates to your internal policies and handbook to include this new entitlement.