Major Changes to Connecticut Paid Sick Leave Begin January 1, 2025

By Robin Imbrogno, SPHR, SHRM-SCP – CEO and Founder, The Human Resource Consulting Group, LLC

The new Connecticut Paid Sick Leave Act is shaking things up significantly. If you’re an employer in Connecticut, here’s what you need to know – including a few potential pitfalls to avoid.

Key Changes to the Paid Sick Leave Law

1. Broader Coverage: The law now includes a lot more employers! Currently, only businesses with 50 or more employees in specific sectors have to provide paid sick leave. But starting January 1, 2025, that requirement will extend to businesses with at least 25 employees. By January 1, 2026, it’ll cover those with 11 or more employees. Finally, by January 1, 2027, every employer in Connecticut, regardless of size, will need to provide paid sick leave.

There are some exceptions, like certain seasonal workers and specific construction trades. Another significant change is that the law now covers all private-sector employees rather than only “service workers” in certain occupations.

2. Accrual Rates: Employees will now earn one hour of paid sick leave for every 30 hours worked, up to a maximum of 40 hours per year. This is more generous than the existing regulation, which requires one hour for every 40 hours worked. Employees can continue to carry over up to 40 hours of unused sick leave into the next year. In addition, employees will be able to use this benefit on their 120th day of employment.

3. Expanded Use: The reasons employees can use paid sick leave have expanded too. Employees can now use their leave for mental health days, to care for a wider range of family members (including adult children, siblings, grandparents, stepparents and parents-in-law, and even those with a close, family-like bond), or during public health emergencies when workplaces or schools are closed.

More formally stated, under the expanded law, employees can take paid sick leave for:

• An employee’s or employee’s family member’s illness, 
  injury, or health condition; 
• The medical diagnosis, care, or treatment of the employee or employee’s family member; 
• Preventive medical care for the employee’s or employee’s family member’s mental or physical health; 
• The employee’s own mental health wellness day;
• Certain purposes when an employee or employee’s family member is a victim of family violence or sexual assault, provided that the employee is not the alleged perpetrator; and 
• A determination by a health authority, employer of the employee, employer of a family member, or a healthcare provider of whether an employee or employee’s family member poses a risk to the health of others due to exposure to a communicable illness, whether or not the employee or family member contracted the communicable illness.

Potential Pitfalls for Employers

1. Record-Keeping Requirements: The law requires employers to keep detailed records of sick leave accrual and usage for at least three years. These balances must be maintained on wage statements, which can be a big administrative task, especially for smaller businesses that might not have sophisticated payroll systems in place. Failing to maintain these records could result in fines and penalties.

2. Compliance and Communication: Employers need to ensure that their employees are aware of their rights under the new law. All new hires after January 1, 2025 will be required to receive notice regarding this policy. Additionally, existing employees will be required to receive the same. Employers will also need to display posters about the paid sick leave rights.

3. Overlapping Leave Policies: For companies that already offer paid time off (PTO) or vacation days, it’s essential to ensure these policies align with the new requirements. While the law doesn’t require additional leave for businesses already offering 40 hours of PTO, these existing policies must meet the law's criteria.

4. Adapting to Phased Implementation: The phased rollout of the law’s requirements – starting with companies with 25 or more employees and eventually encompassing all 
employers – means businesses must stay updated and prepared for each phase. Small businesses need to be proactive in understanding when they will fall under the new requirements.

5. “Replacement” Employees: Employers will not be able to search for a “replacement” employee while someone is out on sick leave.

6. Documentation/Proof Prohibited: Most challenging, employers will be prohibited from requiring an employee to provide any documentation or proof that paid sick leave is being used for permitted purposes under the law.

Navigating these changes will require careful planning and communication. Employers should review their current leave policies, set up robust record-keeping practices, and educate their workforce to ensure compliance with the new law.