2025 End-of-Year Legislative Newsletter

The second half of 2025 brought significant employment law changes across the United States and Canada, and this momentum will continue into 2026. This newsletter highlights the most impactful legislative updates affecting our clients and associates at People2.0. We’ve organized these changes by jurisdiction to help you quickly find what matters most to your operations. 

Whether you’re planning for 2026 compliance or addressing recent changes, we’re here to support you. If you have questions about how these updates affect your business, please reach out to your People2.0 representative or contact our Human Resources team. 

United States Updates

Federal Updates

Automatic EAD extension eliminated 

Effective Date: October 30, 2025 

On October 30, 2025, the U.S. Department of Homeland Security (DHS) issued an Interim Final Rule (IFR) that eliminates automatic extensions of employment authorization for most categories of EAD renewal applicants. 

Applicants who renew after October 30, 2025 will not receive an automatic extension of up to 365 days as they would have previously. For Form I-765 filed on or after this date, the I-797C receipt notice is not valid as proof of work authorization with an expired EAD. 

Certain noncitizens within specific employment eligibility categories who have submitted a timely Form I-765, Application for Employment Authorization, prior to October 30, 2025, to renew their employment authorization and/or EADs under an eligible category code may be granted automatic extensions of their employment authorization and/or EADs for up to 540 days while their renewal applications are pending. 

What does this mean for EAD extensions? 

1. No More Automatic Extensions for Most EADs 
   • If an employee files Form I-765 on or after October 30, 2025, they do not receive an automatic extension of work authorization. 
   • The I-797C receipt notice for such filings cannot be used with an expired EAD to satisfy I-9 requirements. 
2. Reverification Is Mandatory Before EAD Expiration 
   • Employers must reverify work authorization before the EAD expires. 
   • If the employee cannot present a valid, unexpired document, they cannot continue working until they do. 

Source: USCIS Form I-9 Resources 

Employment authorization document periods shortened 

Effective Date: July 22, 2025 

Recent changes to U.S. immigration regulations have shortened the validity of Employment Authorization Documents (EADs) for certain categories, especially those under Temporary Protected Status (TPS) and parole. These changes may impact work authorization timelines and renewal planning.  

USCIS confirms TPS beneficiaries presenting an expired or expiring EAD (categories A12 or C19) along with a Form I-797C receipt showing a timely renewal filing will now receive an automatic extension of only 365 days, or until the TPS designation ends, whichever is shorter. This new rule applies to all Form I-797C receipts dated July 22, 2025 or later. Previously, TPS EADs could benefit from automatic extensions of up to 540 days, but that is no longer the case. 

What This Means for Form I-9 Compliance 

When an employee presents an expired or expiring TPS EAD (A12 or C19) and a Form I-797C receipt notice showing a timely filing of the TPS EAD renewal, employers may update the Form I-9 to reflect continued work authorization. However, this authorization is limited to the shorter of 365 days from the EAD’s “Card Expires” date or the TPS designation end date for the country. This differs from country-specific DHS announcements or court orders, which may provide longer validity periods. 

Recent TPS updates continue to evolve alongside the new one-year cap. A July 31, 2025 court order blocked TPS termination for Honduras, Nepal, and Nicaragua, extending work authorization through November 18, 2025. For Haiti, a court-ordered extension pushed certain TPS EADs to February 3, 2026. Earlier USCIS guidance allowed 540-day extensions for Venezuela and others, but the July 22 rule now overrides that for any TPS renewal filed on or after this date. 

Possible Implications:  

• More Frequent Renewals: Shorter validity means EADs must be renewed more often, increasing the administrative burden and financial planning needs for employees that could result in late filings and lapses in work authorization.  
• Updated I-9 Compliance: Form I-9 re-verification timelines may be impacted, and additional monitoring of extensions should be applied. 

People2.0 offers training surrounding re-verification processes, please reach out to HR@people20.com if you or your team would like a training, we are here to support you. 

Source: USCIS Automatic Extensions 

State Updates

Alabama 

Portable benefit accounts for independent contractors 

Effective Date: December 31, 2025 

As the independent workforce continues to grow, federal and state lawmakers have introduced legislation to expand access to portable benefits that are not tied to a single employer and can travel with the worker across engagements. These benefits typically include: 

• Health, dental, and vision insurance 
• Retirement savings plans 
• Paid time off and emergency savings 
• Disability and life insurance coverage 

Employers engaging independent contractors should evaluate the following: 

• Contract Language: Ensure service agreements clearly define any benefit contributions and include opt-in/opt-out provisions. 
• Tax Treatment: Contributions may be deductible as business expenses; contractors may also deduct contributions on state income tax returns. 
• Compliance Risk: Contributions may imply an employment relationship. Use safe harbor provisions where applicable. 
• Vendor Selection: Partner with certified portable benefit account providers (banks, investment firms, or tech platforms). 

Source: H.R.1 – One Big Beautiful Bill Act 

California

AI employment regulations approved 

Effective Date: October 1, 2025 

The California Civil Rights Council has amended the Fair Employment and Housing Act (FEHA) to explicitly include the use of Artificial Intelligence (AI) and Automated Decision Systems (ADS) in employment decisions.  California will enforce new regulations under FEHA starting October 1, 2025. Implications for Employers & Staffing Agencies under this amendment are:  

• Non-Discrimination Mandate: AI and ADS tools must not result in disparate impact on protected groups (e.g., race, gender, disability). Agencies are liable for discriminatory outcomes even if caused by third-party tools. 
• Bias Audits & Human Oversight: All AI tools used in hiring, screening, or workforce management must undergo bias testing. Human review must be incorporated into decision-making processes. 
• Recordkeeping Obligations: Employers must retain documentation of AI/ADS usage and decision outcomes for at least four years. 
• Transparency & Candidate Rights: Candidates must be informed when AI tools are used in their evaluation. They must be given the opportunity to appeal decisions to a human reviewer. 
• Vendor Accountability: Agencies must ensure that third-party AI vendors comply with California law. Contracts should include indemnification clauses and compliance guarantees. 

How can you stay in compliance:  

• Conducting an AI Tool Audit: Reviewing all platforms used in recruitment and workforce management. 
• Updating Vendor Agreements: Ensuring all contracts include legal protections and compliance guarantees. 
• Staff Training: Launching a training series on ethical and compliant AI use. 
• Implementing Human Oversight: Adding manual review steps to all AI-driven decisions. 
• Policy Updates: Revising our privacy and data retention policies to meet the new standards. 

Please reach out to Human Resources if you have any additional questions.  

Source: California SB-313 Bill Analysis 

Affirmative defenses in AI harm cases enacted 

Effective Date: January 1, 2026 

Effective January 1, 2026, California has enacted Assembly Bill 316 (AB 316), which establishes new legal standards for liability in civil cases involving harm caused by artificial intelligence (AI). This law is a first-of-its-kind measure that directly addresses the growing use of autonomous AI systems and their potential risks. 

Key Provisions 

• No Autonomous AI Defense 
• Defendants cannot claim that an AI system acted autonomously as a defense in civil lawsuits. 
• Developers, deployers, and users of AI systems are legally responsible for harm caused by those systems, even if the AI acted independently or unpredictably. 

Definition of AI 

• AB 316 defines AI as: 

“An engineered or machine-based system that varies in its level of autonomy and that can, for explicit or implicit objectives, infer from the input it receives how to generate outputs that can influence physical or virtual environments.” 

Scope of Liability 

• Applies to individuals and organizations that develop, modify, or use AI systems. 
• Covers harm that is physical, financial, emotional, or reputational. 

Action Items 

• Conduct a risk audit of all AI systems currently in use or development. 
• Update internal policies to reflect AB 316’s liability standards. 
• Coordinate with your legal counsel to prepare for potential litigation scenarios involving AI. 

Source: California AB 316 Bill Text 

Wage payment remedies and penalties enhanced 

Effective Date: January 1, 2026 

Effective January 1, 2026, California’s Senate Bill 261 (SB 261) significantly strengthens enforcement mechanisms for unpaid wage judgments. The law introduces civil penalties of up to three times the unpaid amount, plus mandatory attorneys’ fees and costs for prevailing employees, the Labor Commissioner, or public prosecutors. Employers who fail to satisfy final wage judgments within 180 days of the appeal period may face these enhanced penalties unless they reach and comply with a payment agreement. The law also establishes successor liability, meaning reorganizations or business sales will not shield employers from responsibility. Additionally, 50% of assessed penalties will go directly to affected employees, with the remaining 50% allocated to the Division of Labor Standards Enforcement (DLSE) to support enforcement and education efforts. Employers are strongly encouraged to audit wage practices, resolve outstanding claims promptly, and strengthen compliance programs to avoid escalating liability. 

Source: California AB-2857 Bill Analysis 

Stay-or-pay provisions targeted 

Effective Date: January 1, 2026 

Effective January 1, 2026, California’s Assembly Bill 692 (AB 692) prohibits most “stay-or-pay” clauses in employment contracts. These provisions—commonly referred to as Training Repayment Agreement Provisions (TRAPs)—require employees to repay costs such as training, relocation, or bonuses if they leave their job before a specified period. Under the new law, such clauses are considered unlawful restraints on trade, and employers may face civil penalties of at least $5,000 per affected employee, along with attorneys’ fees and injunctive relief. The law aims to protect worker mobility and prevent financial barriers that discourage employees from pursuing new opportunities. 

AB 692 includes limited exceptions for government-sponsored programs, tuition repayment for transferable credentials under strict conditions, and state-approved apprenticeships. Employers must ensure that any qualifying repayment agreements are separate from employment contracts, interest-free, prorated, and allow time for legal review. Additionally, repayment cannot be required if the employee is terminated, unless for misconduct. Employers are advised to review and revise all employment agreements, onboarding materials, and incentive structures to ensure compliance before the law takes effect. 

Source: California AB 692 Bill Text 

Personnel file requirements enacted 

Effective Date: January 1, 2026 

Effective January 1, 2026, California’s Senate Bill 513 (SB 513) amends Labor Code Section 1198.5 to expand the definition of personnel records that employers must make available to current and former employees. The law now explicitly includes education and training records as part of personnel files subject to inspection and copying upon request.  

Key Requirements 

Training records must include: 

• Employee’s name 
• Trainer’s name 
• Date and duration of training 
• Core competencies (e.g., equipment or software skills) 
• Resulting certification or qualification 

Employers must: 

• Respond to written requests within 30 calendar days (extendable to 35 days by mutual agreement) 
• Retain personnel records, including training documentation, for at least three years after termination 
• Allow one request per year from former employees 
• Verify the identity of the requester and may require use of a company-provided form 

Compliance reminder: 

This update is more than a recordkeeping adjustment—it’s a legal obligation. Failure to comply may result in penalties, including criminal liability.  

Source: California SB 513 Bill Text 

Bias mitigation training clarified 

Effective Date: January 1, 2026 

Effective January 1, 2026, California’s Senate Bill 303 (SB 303) amends the Fair Employment and Housing Act (FEHA) to clarify that an employee’s good-faith participation in bias mitigation training does not, by itself, constitute unlawful discrimination. This includes activities such as self-assessments, testing, or acknowledging personal bias during diversity, equity, and inclusion (DEI) programs. The law is designed to encourage employers to implement meaningful bias training without fear that employee participation could be used as evidence in discrimination claims. 

Additionally, SB 303 provides confidentiality protections for public employers by establishing evidentiary privileges that prevent bias training records from being disclosed in civil proceedings. Employers are encouraged to review their DEI programs and training materials to ensure they align with the new law and to reinforce a psychologically safe environment for participants. Legal and HR teams should also update internal policies and training disclosures to reflect these protections and support continued engagement in bias mitigation efforts. 

California employers are not required to provide bias mitigation training 

Source: California SB 303 Bill Text 

Pay transparency and pay equity requirements amended 

Effective Date: January 1, 2026 

Effective January 1, 2026, California’s AB 642 strengthens existing pay transparency and equity laws by expanding the definition of “wages” and “wage rates” to include all forms of compensation—such as bonuses, commissions, stock options, travel reimbursements, and benefits—when evaluating pay disparities. The law also updates the definition of “sex” to include nonbinary identities, ensuring broader protections under the Equal Pay Act. Additionally, the statute of limitations for filing pay discrimination claims is extended from two to three years, and employees may now recover up to six years of back pay under a continuing violation theory. 

AB 642 also modifies job posting requirements under Labor Code Section 432.3. Employers must now include a “good faith estimate” of the salary or hourly wage range they reasonably expect to pay upon hire, rather than a general range for the position. This change aims to improve transparency and reduce misleading or overly broad pay scales. Employers are advised to review compensation structures, update job postings, and ensure recordkeeping practices align with the extended liability window and expanded definitions. Proactive audits and policy updates will be essential to mitigate legal risk and ensure compliance with AB 642. 

Source: California SB 642 Bill Text 

Consumer Privacy Act regulations finalized 

Effective Date: January 1, 2026 

Effective January 1, 2026, California has finalized long-awaited regulations under the California Consumer Privacy Act (CCPA) that impose significant new obligations on businesses using automated decision-making technology (ADMT). These rules apply when ADMT is used to make “significant decisions” about individuals—such as hiring, lending, housing, education, or healthcare—and require businesses to provide clear pre-use notices, allow opt-outs or appeals, and conduct risk assessments. Starting January 1, 2027, businesses must disclose how ADMT works, what data it uses, and whether human oversight is involved. The law also mandates that consumers be given the right to opt out of ADMT or appeal decisions to a qualified human reviewer. 

For employers, these regulations create new compliance challenges, especially in areas like recruiting, performance management, and compensation decisions. Employers must now assess whether any tools used in employment decisions qualify as ADMT and ensure proper disclosures and opt-out mechanisms are in place. Risk assessments must document the logic behind ADMT systems, the types of personal data used, and safeguards against bias or unfair outcomes. Legal, HR, and IT teams should begin mapping ADMT use across the organization, updating privacy policies, and preparing phased compliance deadlines. Early planning will be critical to avoid enforcement risks and demonstrate responsible AI governance. 

Source: CPPA Announcements 

Leave and workplace protections for hate crime victims expanded 

Effective Date: January 1, 2026 

California’s Assembly Bill 406 significantly expands workplace protections for employees who are victims of hate crimes and other qualifying acts of violence as well as for employees whose family members are victims. 

Who are covered: 

• Victims of qualifying acts of violence, including:  
  • Hate crimes, domestic violence, sexual assault, stalking, serious physical threats or injury 
• Employees with victimized family members, including a designated person (e.g., close friend or relative). 

Employer Obligations: 

• All employers must allow time off for court appearances and protective order proceedings. 
• Employers with 25+ employees must also allow leave for:  
  • Seeking medical, mental health, or victim services 
  • Safety planning and relocation 
  • Attending legal proceedings 
  • Caring for injured family members 
  • Securing housing or childcare due to violence 

Leave Details 

• Up to 12 weeks of protected leave for victims 
• Up to 10 days for employees with victimized family members (5 days if used for relocation) 
• Leave may run concurrently with CFRA and FMLA 

Accommodations & Protections 

• Employers must provide reasonable accommodations for safety at work. 
• Anti-retaliation protections apply, including against subtle actions like schedule changes or exclusion from meetings. 
• Employers must maintain confidentiality regarding the reason for leave. 

Source: California AB-2428 Bill Text 

State power over labor disputes in private sector expanded 

Effective Date: January 1, 2026 

California has enacted Assembly Bill 288 (AB 288), granting the state’s Public Employment Relations Board (PERB) new authority to intervene in private-sector labor disputes an area traditionally governed by federal law through the National Labor Relations Board (NLRB). 

Key Provisions of AB 288 

Under AB 288, PERB may assume jurisdiction over private-sector labor disputes when: 

• The NLRB lacks a quorum or is otherwise unable to function. 
• Federal protections under the National Labor Relations Act (NLRA) are repealed, narrowed, or blocked. 
• The NLRB has ceded jurisdiction, including delays exceeding six months or unresolved appeals. 

PERB is empowered to: 

• Investigate and adjudicate unfair labor practice charges. 
• Certify union representation elections. 
• Enforce collective bargaining agreements. 
• Impose civil penalties (up to $1,000 per violation). 
• Order binding arbitration if negotiations stall. 

This authority is triggered only when federal enforcement is unavailable or ineffective. 

Legal Challenge and Preemption Concerns 

The NLRB has challenged similar legislation in New York, and legal experts anticipate a similar lawsuit against California. The core issue is federal preemption, as the NLRA traditionally grants exclusive jurisdiction to the NLRB over private-sector labor relations.  

Until the courts resolve this challenge, staffing agencies should prepare for potential dual-track enforcement under both federal and state systems. 

Source: California Attorney General Press Release 

Paid Leave Act expanded 

Effective Date: January 1, 2026 

California’s Assembly Bill 406, part of a broader legislative package, significantly expands the Healthy Workplaces, Healthy Families Act (HWHFA) and related laws to provide greater leave protections for employees, especially those affected by crime or violence. 

Effective January 1, 2026 Employees may use accrued paid sick leave for: 

• Attending court proceedings (e.g., hearings, sentencing, post-conviction matters) 
• Meeting with law enforcement, prosecutors, or victim services 
• Seeking or renewing restraining orders 
• Accessing services from domestic violence shelters, sexual assault programs, or advocacy organizations 

Employees (or their family members) who are victims of serious crimes may take unpaid, job-protected leave to attend: 

• Delinquency hearings 
• Post-arrest release decisions 
• Pleas and sentencing 
• Any proceeding where a victim’s rights are at issue 

“Safe Time” now: 

• Includes time off for employees or family members who are victims of certain crimes  
• Recognizes that recovery from violence involves more than medical treatment 

Employers must post and distribute a mandatory notice titled:  

• “Survivors of Violence and Family Members of Victims – Right to Leave and Accommodations” 

Notice must be provided:  

• Upon hire 
• Annually 
• Upon request 

When an employee reports being a victim 

Source: California AB 406 Bill Text 

Workplace Know Your Rights Act enacted 

Effective Date: February 1, 2026 

California’s SB 294 requires employers to provide employees with a stand-alone written notice outlining key workplace rights. The goal is to ensure that all workers are informed of their legal protections under state and federal law. 

Annual Notice: Employers must provide a written notice to:  

• All current employees (by February 1 each year) 
• All new hires upon onboarding 
• Any authorized employee representative (e.g., union rep) 

• Delivery Methods: Notices may be delivered via personal service, email, or text so long as delivery is reasonably expected within one business day. 
• Recordkeeping: Employers must retain proof of notice delivery for three years. 

People 2.0 is already compliant with the written notice at the time of hire, via the employee start sheet that is sent out to all employees in California through the People2.0 software.  

The Labor Commissioner will release a template notice by January 1, 2026, for the annual notice requirement, once that is released, we will ensure this is sent out via the People2.0 software annually.  

We expect the annual notice to include: 

• Rights to workers’ compensation, disability pay, and medical care for work-related injuries 
• Protections against immigration-related retaliation 
• Rights to unionize or engage in concerted activity 
• Constitutional rights (e.g., 4th and 5th Amendments) when interacting with law enforcement at the workplace 
• Contact info for relevant enforcement agencies 
• Updates on new labor laws and regulations 

This law also puts new requirements on emergency contact notifications: 

• Employers must notify the contact if the incident occurs on-site, during work hours, or while performing job duties, and the employer is aware of it. 
• Employees may designate an emergency contact to be notified if they are arrested or detained at work. 

People2.0’s emergency contact form is in the process of being updated to satisfy these requirements.  

Source: California SB 294 Bill Text 

30-day window to provide data breach notification required 

Effective Date: January 1, 2026 

Effective January 1, 2026, California Senate Bill 446 (SB 446) amends Civil Code §1798.82 to require businesses to notify affected individuals of a data breach within 30 calendar days of discovery. This change significantly shortens the previous notification timeline and introduces new obligations for organizations handling personal information of California residents. 

If the breach affects 500 or more California residents, a sample notice must be submitted to the California Attorney General within 15 days of notifying individuals. 

The new law requires data breach notices to be written in plain language, they must be titled “Notice of Data Breach,” and they should follow a standard format, with the information presented under the following headings: 

• What Happened 
• What Information Was Involved 
• What We Are Doing 
• What You Can Do 
• Contact Information 

There are also minimum content requirements. Data breach notices must include contact information for the individual or entity reporting the breach, the types of information reasonably believed to have been compromised, and contact information for the major credit reporting agencies if the breach involved Social Security numbers, driver’s license numbers, or California identification card numbers. If known at the time of issuing the notifications, notices should state the date of the breach, the estimated date of the breach, or the date range in which the breach occurred. Notices should also include a general description of the breach incident. 

Identity Protection Services: 
If sensitive data (e.g., Social Security numbers, driver’s license numbers) is involved, businesses must offer 12 months of identity theft protection at no cost to affected individuals. 

Source: California SB 446 Bill Analysis 

Recall rights for COVID-19 layoffs extended 

Effective Date: January 1, 2026 through January 1, 2027 

California Governor Gavin Newsom signed Assembly Bill (AB) 858 into law, which amends Labor Code section 2810.8 by extending the sunset date of the recall and reinstatement rights for certain employees laid off as a result of the COVID-19 pandemic from December 31, 2025 to January 1, 2027, to ensure that certain hospitality and service workers, who were laid off during the COVID-19 pandemic will continue to have rehiring protections. 

Which industries are covered:

• Hospitality and building services employers, including:  
  • Hotels, private clubs, event centers 
  • Airport hospitality/service providers 
  • Janitorial, building maintenance, and security services 
• Laid-off employees who: 
  • Worked at least 6 months 
  • Were separated on or after March 4, 2020 
  • Lost employment due to COVID-related reasons (e.g., shutdowns, lack of business) 

Employer Requirements: 

• Must offer available positions to qualified laid-off employees within 5 business days 
• Offers must be made in order of seniority 
• Employees have at least 5 business days to respond 
• Employers must retain records for 3 years 
• If declining to rehire, employers must provide a written explanation within 30 days 

The law prohibits retaliation for exercising rights under section 2810.8 and authorizes enforcement by the Division of Labor Standards Enforcement (DLSE), including reinstatement/hiring, back and front pay, and the value of benefits. 

Source: California AB 858 Bill Text 

Colorado

Paid Family and Medical Leave Insurance amended 

Effective Date: January 1, 2026 

The State of Colorado has enacted amendments to its Paid Family and Medical Leave Insurance (FAMLI) program, effective January 1, 2026, that introduce new benefits and adjust employee premium rates. The amendment to the FAMLI now offers additional paid leave for parents of newborns receiving care in a Neonatal Intensive Care Unit (NICU). Employees could receive up to a total of 24 weeks of paid FAMLI leave (12 weeks of bonding leave and 12 weeks of time that the newborn is in the NICU).  

Starting January 1, 2026, the premium amount will decrease to 0.88% from 0.9% of wages per employee. 

Source: Colorado SB25-144 

Connecticut 

Anti-SLAPP statute amended 

Effective Date: October 1, 2025 

Connecticut has amended its anti-SLAPP statute through House Bill 7134 to broaden protections for individuals engaged in certain public communications. The updated law now shields individuals from civil lawsuits when they make written statements without malice about: 

• The alleged commission of a crime, or 
• A discriminatory practice under state human rights laws. 

Key provisions include: 

• The right to file a special motion to dismiss such lawsuits. 
• Mandatory attorney’s fees awarded to the prevailing party. 
• A stay on discovery and an expedited hearing process. 
• Delayed hearings if the communication relates to an ongoing criminal or CHRO proceeding. 

This amendment strengthens free speech protections and helps prevent retaliatory lawsuits aimed at silencing individuals who report misconduct or discrimination. 

Source: Connecticut HB 7134 

Delaware

Healthy Delaware Families Act regulations interpreted 

Effective Date: January 1, 2026 

Delaware’s Healthy Delaware Families Act (HDFA) establishes a statewide Paid Family and Medical Leave (PFML) program. The first round of regulations clarifies how the law will be implemented and enforced. 

Coverage 

• Applies to employers with 10+ employees in Delaware. 
  • 10–24 employees: Must comply with Parental Leave only. 
  • 25+ employees: Must comply with all PFML requirements. 
• Coverage is determined by employee count over the previous 12 months. 
• Employees must work at least 60% of their hours in Delaware and meet service requirements (12 months, 1,250 hours). 

Special Employee Categories 

• Reclassified Employees: Out-of-state or telecommuting employees can be voluntarily designated as Delaware-based for PFML purposes. 
• Waiver of Coverage: Temporary or part-time employees may be excluded via a waiver, but if eligibility requirements are later met, coverage and contributions apply retroactively. 

Types & Duration of Leave 

• Parental Leave: Up to 12 weeks (can be reduced to 6 weeks for smaller employers until 2031). 
• Family Caregiving, Medical Leave, Qualified Exigencies: Up to 6 weeks in a 24-month period. 
• Leave reasons include birth/adoption/foster care, serious health conditions (self or family), and military deployment-related issues.  

Payroll Contributions & Benefits 

• Contributions started January 1, 2025 or when coverage thresholds are met. 
• Rates for 2025–2026: .32% (Parental), .4% (Medical), .08% (Family Caregiver/Exigencies). 
• Employers pay at least 50% of contributions; may elect to pay more. 
• Benefits are based on Delaware FICA wages, calculated at 80% of average weekly wage (min $100, max $900, adjusted annually). 

Notice & Coordination 

• Employees must generally provide 30 days’ notice for leave, or as soon as practicable. 
• Employers may delay coverage if notice is not timely, and no reasonable excuse is given. 
• Coordination with other leave programs (FMLA, disability, PTO) is pending further rulemaking. 

Private Plans & Exemptions 

• Employers may use private PFML plans if they are at least as generous as the state plan. 
• Grandfathering is available for pre-existing plans (before May 10, 2022) until December 31, 2029, if comparable. 
• Key dates for applications and notifications are outlined for both private plans and grandfathering. 

Key Dates to Remember 

• January 1, 2025: PFML contributions begin. 
• January 1, 2026: PFML benefits available. 
• December 31, 2029: End of grandfathering for qualifying pre-existing plans. 

Source: Delaware Healthy Families Act 

Illinois 

Workplace Transparency Act amended 

Effective Date: January 1, 2026 

The law now explicitly protects employees, former employees, and job applicants who engage in concerted activities to address workplace issues, including discrimination and harassment. 

Limits on Confidentiality Clauses 

Settlement and termination agreements may include confidentiality provisions only if they expire within five years of the alleged unlawful employment practice. This change aims to balance privacy with transparency and accountability. 

The amendments require that mutual conditions of employment acknowledge the right to engage in protected activities, ensuring that agreements do not inadvertently restrict lawful employee conduct. 

Employees may now seek consequential damages for violations of the Act, expanding the scope of potential employer liability. 

Source: Illinois HB 3638 

Organ and blood donor leave law expanded 

Effective Date: January 1, 2026 

Under House Bill 1616, the law expands paid leave entitlements for organ and blood donation: 

Organ Donation Leave: 

• Full-time and part-time employees may now use up to 10 days of paid leave in any 12-month period to serve as an organ donor. 
• For part-time employees, employers must calculate and compensate based on the employee’s average daily pay over the previous two months. 

Blood Donation Leave: 

• Employees may continue to use up to one hour of paid leave every 56 days to donate blood, in accordance with recognized medical standards. 

Employer Approval & Documentation: 

• Leave must be approved by the employer, and medical documentation may be required prior to approval. 

People2.0 encourages you to take paid leave mandates into consideration when staffing in states where paid leave is required to be paid out.  

Source: Illinois HB 1616 

Retaliation provisions under Victims’ Economic Security and Safety Act Expanded 

Effective Date: January 1, 2026 

Illinois has amended the Victims’ Economic Security and Safety Act. This act provides an employee who is a victim of domestic or sexual violence, or who has a family or household member who is a victim of domestic or sexual violence, with unpaid leave to address issues arising from domestic or sexual violence.  

The amendment prohibits an employer from taking adverse action against an employee who uses an employer-issued electronic device to record incidents of: 

• Domestic violence 
• Sexual violence 
• Gender violence 
• Other crimes of violence committed against the employee or their family or household members.  

Specifically, employers cannot discharge, harass, discriminate, or retaliate against an employee or refuse to hire an employee, for use of employer-issued equipment for this purpose. 

This amendment also prevents an employer from depriving an employee of their employer-issued devices solely because the employee used or attempted to use the device for this purpose. An employee is granted the right to access any photographs, recordings, or digital documents stored on employer-issued devices that relate to these incidents. The amendment clarifies that employers are still permitted to comply with investigations, court orders, or subpoenas regarding the devices or information. Employees remain obligated to follow reasonable employment policies and perform the essential functions of their jobs. 

Source: Illinois HB 1278 

Transportation Benefits Program Act amended 

Effective Date: January 1, 2026 

The Illinois Transportation Benefits Program Act requires covered employers in a specified geographic area to provide a pre-tax commuter benefit to covered employees, which allows the employees to use pre-tax dollars to purchase a transit pass through a payroll deduction.  

Under the Act, “covered employees” include any person who performs an average of at least 35 hours of work per week for compensation on a full-time basis. This amendment expands coverage under the Act to part-time employees by changing the definition of covered employee to mean any person who is employed by a covered employer. 

In addition, the amendment creates an exemption to the Act. The Act does not apply to covered employers in the construction industry with respect to employees with whom the covered employer has entered into a bona fide collective bargaining agreement. 

Source: Illinois HB 3615 

Digital Voice and Likeness Protection Act amended 

Effective Date: January 1, 2026 

The Illinois Digital Voice and Likeness Protection Act is designed to safeguard performers and other individuals from the unauthorized or wrongful use of artificial intelligence (AI) replicas of their voice or likeness. The Act specifically addresses agreements related to the use of digital replicas in the context of personal or professional services. 

Original Provisions 

Any agreement allowing the creation and use of a digital replica of an individual’s voice or likeness in place of work the individual would have performed in person is considered unenforceable if: 

• The agreement does not provide a specific description of all intended uses of the digital replica. 
• The individual was not represented by legal counsel or a labor union at the time of the agreement. 

Amendments to the Act 

• The amendment removes the phrase “contrary to public policy,” but maintains that such agreements are unenforceable if the criteria above are met. 
• The amendment clarifies that if an agreement lacks a reasonably specific description of the intended uses of a digital replica, the agreement is not automatically unenforceable. This is the case as long as the uses of the digital replica are consistent with: 
  • The terms of the contract for the performance of personal or professional services. 
  • The fundamental character of the photography or sound track as originally recorded or performed. 

Effective Date and Scope 

The amendment specifies that the Act applies only to new performances executed by a digital replica of an individual on or after January 1, 2026. 

Looking Ahead 

• Individuals are further protected against unauthorized digital replication of their voice or likeness in new contracts. 
• Agreements must clearly outline intended uses of digital replicas unless those uses align with the original terms and character of the work. 
• Representation by legal counsel or a labor union remains a critical factor for enforceability. 

This amendment reflects ongoing legislative efforts to balance technological innovation with the rights and protections of individuals in the digital age. 

Source: Illinois HB 3178 

Lactation Accommodation Law amended to provide paid lactation breaks 

Effective Date: January 1, 2026 

Effective January 1, 2026, Illinois Senate Bill 212 amends the Nursing Mothers in the Workplace Act to require paid lactation breaks for nursing employees. 

Key highlights: 

• Employees must be provided 30 minutes of paid break time each time they need to express breast milk, for up to one year after childbirth. 
• Breaks must be paid at the employee’s regular rate of pay. 
• Employers cannot require employees to use vacation, sick leave, or other paid time off for lactation breaks. 
• Compensation cannot be reduced for time spent expressing milk. 
• Lactation breaks may run concurrently with other scheduled breaks. 
• Employers may be exempt only if providing paid breaks would cause an undue hardship, as defined by the Illinois Human Rights Act. 

Source: Illinois SB 212 

Law on use of AI in employment decisions clarified 

Effective Date: January 1, 2026 

The Illinois Human Rights Act (IHRA) now restricts how employers may use artificial intelligence (AI) in employment decisions to prevent discrimination based on protected characteristics (such as race, gender, or age). 

Key Provisions 

• Employers cannot use AI in ways that discriminate in hiring, promotion, compensation, or other employment practices. 
• Notice must be given to applicants and employees when AI is used in any employment-related decision. 
• Employers cannot use zip codes as a stand-in for protected classes in AI-driven decisions, as this could result in indirect discrimination. 

This law applies to staffing firms and employers.  

Source: Illinois HB 3773 

Maine

Mandatory Earned Paid Leave Law amended 

Effective Date: September 24, 2025 

On July 1, 2025, Maine Governor Janet Mills signed LD 55 into law, amending the state’s earned paid leave statute. This increases the maximum leave balances from the current 40 hours to 80 hours at a given time.  

If you have any questions, please contact the People2.0 Human Resources department. 

Source: Maine LD 55 Bill Amendment 

Reporting Time Pay Law passed 

Effective Date: September 24, 2025 

Maine Governor Janet Mills signed the new Reporting Time Pay Law (LD 598) into law on June 24, 2025. The law went into effect on September 24, 2025. This may impact scheduling and compensation for practices for hourly employees. 

Effective immediately, the law requires employers to compensate employees with a minimum of four hours of pay at their regular rate if they report to work as scheduled but are dismissed early due to lack of work or other operational decisions. 

This law applies to: 

• Hourly employees who physically report to a worksite. 
• Situations where the employee is sent home without performing their full scheduled shift. 

Exceptions to this law are employers are not required to provide reporting time pay in cases of:  

• Weather-related closures or emergencies 
• Employee-requested schedule changes 
• Pre-scheduled on-call shifts where no work is assigned. 

We encourage you to review your scheduling practices to ensure compliance and provide guidance to your managers on how to navigate shift cancellations and early dismissals appropriately. 

Source: Maine Legislature Bill Summary 

Anti-SLAPP statute amended to address sexual assault and discrimination 

Effective Date: September 24, 2025 

Maine has amended its anti-SLAPP statute through Legislative Document (LD) 385, significantly broadening protections for individuals who speak out about sexual assault, harassment, misconduct, cyberbullying, and discrimination. 

Key Highlights: 

• Expanded Protected Speech: The law now covers communications made by alleged victims regarding: 
  • Sexual assault 
  • Sexual harassment or misconduct 
  • Cyberbullying 
  • Discrimination, including harassment, retaliation, coercion, or failure to prevent discrimination 
• Protection from Retaliatory Lawsuits: Individuals who report or publicly share experiences of misconduct are shielded from defamation and other retaliatory legal actions. 
• Preservation of Legitimate Claims: The amendment maintains the ability to pursue valid defamation claims, while preventing misuse of defamation laws to silence valid claims of harm. 

This change is meant to empower survivors and whistleblowers to speak out without fear of legal retaliation, reinforcing Maine’s commitment to protecting vulnerable individuals and promoting accountability. 

Source: Maine LD 385 

Intermittent leave provisions amended in Paid Family and Medical Leave Law 

Effective Date: September 24, 2025 

On June 18, 2025, Governor Janet Mills signed LD 894 into law, introducing several amendments to Maine’s Paid Family and Medical Leave Program. Among the key changes is a clarification of how intermittent leave may be taken under the program. 

Premium contributions started January 1, 2025, and benefits are scheduled to start May 1, 2026. 

Below is comparison table showing the old intermittent leave rules vs. the updated amendments:  

Feature	Previous Rule	Updated Amendment (LD 894)
Intermittent Leave Availability	Allowed, but lacked clear structure or minimum increment guidance	Explicitly allowed; clarified structure and minimum increment requirements
Minimum Leave Increment	Not clearly defined	Minimum increment is 1 hour; smaller increments not permitted
Mutual Agreement Flexibility	No formal provision for employer-employee agreement on smaller increments	Leave can be taken in less than a full day only if mutually agreed, but not less than 1 hour
Impact on Total Leave Entitlement	Unclear	Intermittent leave does not reduce total leave entitlement
Administrative Oversight	No dedicated bureau	Establishes Bureau of Paid Family and Medical Leave within Maine DOL
Enforcement & Penalties	Limited enforcement mechanisms	Adds civil penalties, enforcement tools, and liability rules for employers

Source: Maine Paid Family and Medical Leave Statutes 

Additional Resource: Maine PFML Employee FAQ 

Paid family and medical leave benefits begin 

Effective Date: May 1, 2026 

Governor Janet Mills signed L.D. 1964, establishing the Maine Paid Family and Medical Leave Benefit Program, on July 11, 2023. Eligible employees receive 12 weeks of paid leave annually, funded by a state-run 1% payroll tax split between employers and employees. Payroll contributions start January 1, 2025; benefits begin May 1, 2026. Employers with 15 or more employees will contribute 0.5%, with the remaining 0.5% withhold from employee wages. Employers with fewer than 15 employees are only responsible for withholding the employee portion (0.5%). 

To qualify the individual must:  

• Work for a Maine-based employer covered by PFML.  
• Have earned at least 6 times the State Average Weekly Wage in the first 4 of the last 5 completed calendar quarters.  
• Be employed at the time of application.  
• Not be disqualified due to fraud.  
• Have a qualifying reason for leave. 

Source: Maine Paid Family and Medical Leave Program 

Maryland 

Employment equality for service members ensured 

Effective Date: October 1, 2025 

Maryland has enacted the Employment and Insurance Equality for Service Members Act, significantly expanding employment protections for all uniformed service members, including reserve components, not just the Armed Forces. This law aligns Maryland’s definitions of “service member,” “veteran,” “active duty,” and “uniformed services” with federal standards, ensuring consistency across state statutes. 

Key Employment Protections 

• Hiring Preferences: Employers may give preference to veterans, spouses of disabled veterans, active service members, and surviving spouses. 
• Deployment Leave: Employees are entitled to leave when an immediate family member departs for or returns from active duty in any uniformed service. 
• Licensing & Training Recognition: Military training counts toward licensing and apprenticeship requirements; renewal deadlines are extended for those returning from active duty. 
• Unemployment Insurance: Inactive duty training does not affect employment status or benefit eligibility; drill pay is not deducted. 
• Anti-Discrimination in Insurance: Insurance providers must not discriminate against service members or their families. 

This law reflects Maryland’s commitment to supporting military families and ensuring equal access to employment, licensing, and benefits. 

Source: Maryland HB 0895 

Employer coverage provisions of Parental Leave Act amended 

Effective Date: October 1, 2025 

Effective October 1, 2025, Maryland has revised its Parental Leave Act (PLA) through Senate Bill 785 to clarify which employers are subject to the state’s unpaid parental leave requirements. 

Key Change: Employer Coverage Redefined 

• The PLA will now apply only to employers with 15 to 49 employees in Maryland. 
• Employers covered by the federal Family and Medical Leave Act (FMLA), typically those with 50 or more employees are exempt from the PLA, even if their workforce fluctuates below 50 during the year. 

This amendment resolves long-standing confusion and overlap between state and federal leave laws. Previously, some employers were subject to both the PLA and FMLA, creating compliance challenges due to differing eligibility and procedural requirements. 

Impact on Employers 

• Smaller employers (15–49 employees) must continue to provide up to six weeks of unpaid parental leave for birth, adoption, or foster placement. 
• Larger employers (50+ employees) already covered by FMLA are no longer required to comply with the PLA. 

Since People2.0 is a large employer and meets the FMLA eligibility requirements, we are no longer subject to Maryland Paid Leave Act. 

Source: Maine LD 55 Bill Amendment 

Massachusetts 

Wage Equity Law enacted 

Effective Date: October 29, 2025 

The Massachusetts Wage Equity Law, formally known as the Frances Perkins Workplace Equity Act, went into effect on October 29, 2025, and builds upon the 2016 Massachusetts Equal Pay Act (MEPA). It introduces new wage transparency and reporting requirements aimed at closing gender and racial pay gaps across the Commonwealth. 

Employee Rights: 

• Current employees can request the pay range for their position. 
• Applicants must be informed of the pay range during hiring. 
• Employees being promoted or transferred must receive the pay range for the new role. 

Definition of Pay Range: The expected annual salary or hourly wage for a position. Employers must also disclose piece rate or commission ranges if applicable. However, bonuses, benefits, and equity compensation are excluded from disclosure. 

Source: Massachusetts S2721 Bill Text 

Minnesota 

Meal and rest break requirements expanded 

Effective Date: January 1, 2026 

Effective January 1, 2026, Minnesota is implementing amendments to its labor laws significantly expanding employee rights to meal and rest breaks. These changes aim to provide more structured and enforceable break periods for workers. 

Key Changes 

Rest Breaks: 

Current Law: “Adequate time” to use the restroom every 4 hours. 

New Requirement (2026):  

• At least 15 minutes of paid rest break within every four consecutive hours worked. 
• Must be longer than 15 minutes if needed to use the nearest convenient restroom. 
• Breaks must occur within the 4-hour window, not at the end. 
• Must be paid at the employee’s regular rate. 

Meal Breaks: 

Current Law: “Sufficient time” to eat a meal when working 8+ hours. 

New Requirement (2026):  

• At least 30 minutes of unpaid meal break when working six or more consecutive hours. 
• Must be uninterrupted to remain unpaid. 
• Only one meal break required per shift unless further guidance is issued. 

Clients Responsibilities:  

• Educate managers and supervisors on compliance and enforcement.  
• Clarify employee rights and voluntary waiver scenarios.  
• Track break time to demonstrate compliance.  

Source: Illinois SB 2939 

Paid Family and Medical Leave program launched 

Effective Date: January 1, 2026 

Minnesota will launch a state-run Paid Family and Medical Leave (PFML) program on January 1, 2026, offering workers up to 20 weeks of job-protected, partially-paid leave each year for eligible family and medical reasons. 

Effective January 1, 2026 – Employees and Employers will begin to pay into the funds, with the first premium payment due by April 30, 2026.  

With certain exceptions, all Minnesota employees who satisfy the financial eligibility criteria established by law will qualify for PFML benefits. To be eligible, an employee must have earned at least 5.3% of the state average annual wage during their base period, which is defined as the four most recently completed calendar quarters preceding the submission of their benefits application.  

Employees may receive up to 12 weeks of paid leave for their own serious health issues and an additional 12 weeks for reasons such as bonding, caring for family, ensuring safety, or qualifying exigencies. However, the total paid leave available within a benefit year is capped at 20 weeks. For example, if someone uses the full 12 weeks for medical reasons, only eight weeks remain for other eligible leave types. 

Source: Minnesota Paid Leave 

Montana 

Volunteer emergency service providers leave enacted 

Effective Date: October 1, 2025 

Montana has enacted legislation that prohibits employers from terminating the employment of volunteer emergency service providers who are absent from work during an emergency. House Bill 128 will be codified in Title 2 of the Montana Code Annotated for public employers and Title 39 of the Montana Code Annotated for private employers, with an effective date of October 1, 2025.  

The law covers employees serving as volunteer firefighters, emergency medical technicians, and members of municipal, rural, or subscription fire departments who do not receive full-time pay for their emergency service work. 

Employers may not terminate the employment of an employee who has completed the probationary period because the employee provides volunteer emergency services or has joined a volunteer emergency unit. Employees must provide written notice to the employer of their status as a volunteer emergency services provider as follows: 

• Current employee volunteers: Within 30 days of October 31, 2025; 
• Current employees who volunteer after October 1, 2025: Within 30 days of volunteering; and 
• New employee volunteers: Within 30 days of hire 

Employer Rights and Responsibilities 

• Employers may request a written statement from the volunteer organization confirming the emergency response, including date, time, and duration. 
• Time spent responding to emergencies is unpaid for non-exempt employees. 
• Employers may decide whether employees can leave work mid-shift to respond to emergencies. 

Source: Montana HB 128 

Law on vaccination status discrimination amended 

Effective Date: October 1, 2025 

Montana has passed Senate Bill 382, expanding protections against discrimination based on vaccination status and immunity passports. This builds on earlier legislation (HB 702) and reflects ongoing debates around personal medical choices and public health policy. 

• Vaccination Status as a Protected Category: Employers, public accommodations, and government entities are prohibited from: 
  • Inquiring about vaccination or immunity status 
  • Denying employment, services, or access based on vaccination status  
• Immunity Passports: It is unlawful to require or discriminate based on possession of an immunity passport. 
• Scope of Coverage: Applies broadly across employment, education, healthcare access, and public services. 
• Exceptions: The law allows for limited exceptions in settings like schools and daycare facilities, where vaccination requirements may still apply  

 Legal Context 

• The law has faced legal challenges, including claims of federal preemption under the Americans with Disabilities Act (ADA) and Occupational Safety and Health Act (OSHA). 
• In Montana Medical Assn. v. Knudsen, the Ninth Circuit Court of Appeals upheld the law, ruling that plaintiffs lacked standing due to speculative harm 

Source: Montana Code Annotated 

Nebraska 

Paid Sick Time Amendment enacted 

Effective Date: October 1, 2025 

Nebraska Governor Jim Pillen signed Legislative Bill (LB) No. 415 that clarifies and amends the Nebraska Healthy Families and Workplace Act (NHFWA) passed by voters in November 2024, which provides earned paid sick time (PST) to most Nebraska employees.  

Accrual and Usage:  

Accrual Rate: 1 hour of paid sick time for every 30 hours worked.  

Annual Accrual Cap: 56 hours 

Annual Usage Cap: 56 hours 

Accrual Begins: October 1, 2025 or upon employment start date 

Carryover: any unused balance  

Usage reason: 

• Mental or physical illness, injury, or health condition 
• Medical diagnosis, treatment, or preventive care 
• Care for a family member with similar needs 
• Public health emergencies (e.g., business or school closures) 
• Self-isolation due to communicable disease exposure 

Source: Nebraska LB 415 

Poster: Nebraska Paid Sick Time Poster 

Nevada

Leave for volunteer members of the Civil Air Patrol expanded 

Effective Date: October 1, 2025 

Assembly Bill 422 amends Chapter 413 of the Nevada Revised Statutes to provide enhanced employment protections for individuals who serve as volunteer members of the Nevada Wing of the Civil Air Patrol. 

Key Provisions: 

• Protected Leave for Training and Missions: 
  • Up to 10 workdays per federal fiscal year for training related to emergency missions. 
  • Up to 30 workdays per federal fiscal year for responding to emergency missions, including search and rescue and disaster response. 
• No Loss of Employment Benefits: 
  • Leave must be granted without loss of position, seniority, accrued leave, or other employment benefits. 
• Unpaid Leave Option: 
  • Employers may treat this leave as unpaid, but cannot require employees to exhaust other leave (e.g., vacation or sick leave) before using Civil Air Patrol leave. 
• Verification Requirements: 
  • Employees must provide certification and verification from the Civil Air Patrol confirming the need for their service. 
• Legal Remedies for Violations: 
  • Employees denied leave may seek damages equal to lost wages and benefits, plus reasonable attorney’s fees and costs. 
• Employer Restrictions Removed: 
  • The bill eliminates prior provisions that allowed employers to prohibit participation in Civil Air Patrol activities during work hours. 

Source: Nevada AB 422 Amendment 

Written workplace safety program regulations released 

Effective Date: January 1, 2026 

The Nevada Division of Industrial Relations (DIR) has adopted new regulations under NRS 618.295 and NRS 618.383, requiring employers to enhance their written workplace safety programs. These updates are part of a broader effort to address occupational exposure to hazardous conditions, particularly heat illness risks, and will take effect on January 1, 2026.  

Key Regulatory Changes 

1. Hazard Analysis Requirement: 

• Employers must conduct a one-time written job hazard analysis to assess working conditions that may cause heat illness. 
• The analysis must include:  
  • Job classifications at risk. 
  • Environmental conditions. 
  • Duration and intensity of exposure. 
  • Mitigation strategies.   

2. Written Safety Program Enhancements: 

• Must include provisions addressing heat-related hazards. 
• Employers must designate a qualified individual to:  
  • Monitor conditions. 
  • Coordinate emergency medical services. 
  • Implement response protocols. 

3. Employee Training Requirements: 

• Employers must provide targeted training for employees in high-risk roles. 
• Training must cover:  
  • Recognition of heat illness symptoms. 
  • Prevention strategies. 
  • Emergency response procedures.  

4. Exemptions: 

• Climate-controlled environments may be exempt. 
• Mining industry employers and those with fewer than 10 employees are generally excluded unless engaged in explosive manufacturing. 

People2.0 heavily relies on our worksite clients to ensure compliance since they have full oversight and control over the worksite and these requirements under the law.  

Source: Nevada Division of Industrial Relations Regulations 

New Hampshire 

Leave for medical appointments related to childbirth enacted 

Effective Date: January 1, 2026 

Starting January 1, 2026, Nevada’s Assembly Bill 388 extends protected leave for medical appointments related to childbirth. The law now covers prenatal care, postnatal checkups, and recovery visits for both birthing and non-birth parents. Employees who have worked at least 90 days are eligible for up to 12 weeks of paid leave for qualifying childbirth-related care, with 100% wage replacement for those earning up to 110% of the state’s average weekly wage. 

Source: New Hampshire RSA Section 275:37-f 

Leave for spouses of military service members created 

Effective Date: January 1, 2026 

Effective January 1, 2026, New Hampshire’s House Bill 225-FN establishes job-protected leave for employees whose spouses are involuntarily mobilized for military service. The law applies to employers with 50 or more employees at a single location and prohibits adverse employment actions—such as termination, refusal to hire, or demotion—based solely on a spouse’s deployment. Eligible employees may take unpaid leave for the duration of their spouse’s mobilization, up to five years, and must be reinstated to their previous role or a comparable position upon return, consistent with federal protections under USERRA.  

To comply, employees must notify their employer within 30 days of receiving official deployment notice, and employers must provide written acknowledgment of the notice. Employers are encouraged to update handbooks, train HR and management staff, and prepare for enforcement guidance from the New Hampshire Department of Labor. This law reflects the state’s commitment to supporting military families and ensuring employment stability during periods of service-related disruption. 

Source: New Hampshire HB 225-FN Bill Text 

New Jersey

Captive audience provisions modified 

Effective Date: December 2, 2025 

Effective December 2, 2025, New Jersey has enacted a new law (A4429/S3302) that prohibits employers from requiring employees to attend meetings or receive communications related to union organizing, political matters, or religious beliefs. This law is designed to protect employees from coercive or retaliatory practices in the workplace. 

Key Provisions 

Prohibited Mandatory Meetings 

Employers may not require attendance at meetings or communications that: 

• Discuss union membership or labor organizing 
• Promote or oppose political candidates or legislation 
• Express religious views or practices 

Employee Rights 

• Employees may refuse to attend such meetings without fear of retaliation. 
• Employers cannot discipline, terminate, or otherwise retaliate against employees who opt out. 
• Employees may file a civil lawsuit within 90 days of a violation. 

Employer Responsibilities 

• A notice of employee rights must be posted in a conspicuous location in the workplace. 
• Employers may still:  
• Hold voluntary meetings 
• Share legally required information 
• Conduct mandatory training (e.g., anti-harassment) 
• Communicate job-related performance expectations 

Source: New Jersey Governor’s Press Release 

New York

Protected categories in state constitution expanded 

Effective Date: December 16, 2025 

On November 5, 2024, New York voters approved Proposition 1, a ballot measure amending Article I, Section 11 of the New York State Constitution to significantly broaden the scope of protected categories under the state’s equal protection clause. 

The revised constitutional language now prohibits discrimination based on: 

• Race, color, ethnicity, national origin 
• Age, disability, creed, religion 
• Sex, including: 
  • Sexual orientation 
  • Gender identity and expression 
  • Pregnancy and pregnancy outcomes 
  • Reproductive healthcare and autonomy 

Source: New York Ballot Proposal 2024 

Ohio

WARN and unemployment provisions changed, sex-related terms redefined 

Effective Date: September 29, 2025 

 WARN Act Provisions 

• The bill introduces state-level Worker Adjustment and Retraining Notification (WARN) requirements, aligning with federal standards but potentially expanding employer obligations. 
• Employers may need to provide advance notice of mass layoffs or plant closures, with penalties for non-compliance. 

Unemployment Benefit Changes 

• The budget includes measures to reduce the duration of unemployment benefits, aiming to encourage faster workforce re-entry  
• It also modifies the State Unemployment Tax Act (SUTA) structure, affecting how employers are taxed based on their experience rating 

Redefinition of Sex-Related Terms 

• The bill codifies that Ohio will recognize only two sexes: male and female as “not changeable and grounded in fundamental and incontrovertible reality” 
• This language mirrors a federal executive order and excludes recognition of transgender and intersex individuals under state law. 

Source: Ohio HB 96 

Salary History and Transparency Law passed (Cleveland) 

Effective Date: October 27, 2025 

Cleveland has enacted a new ordinance that prohibits employers with 15 or more employees from: 

• Asking job applicants about their current or past compensation. 
• Using salary history to determine pay or employment decisions. 
• Retaliating against applicants who refuse to disclose salary history. 

Additionally, employers must now include salary ranges or scales in all job postings and advertisements. Exceptions apply for internal promotions, voluntary disclosures, and positions governed by collective bargaining agreements.  

The law is enforced by the Cleveland Fair Employment Wage Board, with penalties ranging from $1,000 to $5,000 depending on the number of prior violations. 

Source: Cleveland City Legislation 

Oregon

Paid leave Oregon amended 

Effective Date: September 26, 2025 

Upon returning from Paid Leave Oregon (PLO) leave, an employee is generally entitled to be restored to the position held before the start of the leave, as long as the position still exists. The amended law permits an employer to require, as part of a uniformly applied practice or policy, that the employee receive certification from the employee’s health care provider that the employee is able to resume work. This certification requirement does not affect the employer’s ability to require periodic reports from the employee while on leave regarding the employee’s status and intent to return to work. 

The PLO requires that employee information in the records of the Oregon Employment Department or a third-party administrator be kept confidential. The amended law allows the Department to disclose the benefit amounts paid to employees as necessary to allow the employer to calculate full wage replacement during leave taken under PLO. 

The amended law also authorizes the Bureau of Labor and Industries (BOLI), as of January 1, 2026, to provide administrative and regulatory supervision for employee job protection and protection from retaliation and discrimination under the PLO. 

Source: Oregon SB 69 

OFLA amended 

Effective Date: September 26, 2025 

Under the Oregon Family Leave Act (OFLA), an employee may take unpaid leave to care for a child who requires care due to illness, injury, or school or child care closure. The amended law defines “child” for leave purposes as an employee’s child who is under the age of 18 or who is substantially limited by a physical or mental impairment that would qualify as a disability under the OFLA.  

The OFLA allows an employee to take unpaid leave without prior notice to the employer under certain circumstances. When leave is taken to care for a child due to a school or child care closure, the amended law allows such leave without prior notice unless the closure is due to a public health emergency declared by the Governor at least 30 days before the beginning of the leave. 

To qualify for leave under the OFLA, an employee must work an average of 25 hours or more per week during the 180 days immediately before the starting date of the leave. The amended law adds an exception to this OFLA eligibility requirement for airline flight crew employees who are based in Oregon, who are subject to the federal regulations applicable to airline flight crew employees, and who meet the federal requirement for hours of service. 

Source: Oregon SB 69 

Paid sick leave amended 

Effective Date: September 26, 2025 

State law allows employees to use sick time for a number of reasons, including any qualifying purpose under the OFLA. The amended law specifies that sick time can also be used for any qualifying purpose under the PLO. As with other sick time used for more than three consecutive scheduled workdays, an employer may require verification from a health care provider if sick time is used for a PLO-qualifying purpose. 

Source: Oregon SB 69 

Age-related hiring inquiries prohibited 

Effective Date: September 28, 2025 

Oregon has amended its antidiscrimination statute to prohibit pre-employment inquiries that may elicit information about a job applicant’s age. The statute prohibits employment discrimination on the basis of age, and the amendment prohibits an employer or an employment agency from asking for an applicant’s age, date of birth, dates of educational institution attendance, or graduation date unless: 

• An initial interview was already completed; or 
• There was no initial interview, and a conditional employment offer was already extended. 

These restrictions do not apply when such information is required to affirm the applicant meets bona fide occupational qualifications or to comply with any federal, state, or local rule or regulation. 

The amendment also repeals a provision that allowed apprenticeship programs to exclude older applicants. Apprenticeship programs will no longer be allowed to reject an apprentice because they would be unable to complete required apprenticeship training before the age of 70. 

Source: Oregon HB 3187 

Paid Sick Leave Law amended to allow use for blood donation 

Effective Date: January 1, 2026 

In accordance with Oregon Senate Bill 1108, our Paid Sick Leave policy has been updated to include blood donation as a qualifying use of accrued sick time.  

Starting January 1, 2026, employees may use up to four hours per calendar year of accrued paid sick leave to donate blood through an approved voluntary program. 

Eligibility Criteria: 

• Blood donation must be made through a program accredited by the American Association of Blood Banks or the American Red Cross. 
• Leave must be taken in hourly increments and used only for the actual time spent donating. 
• Employees must provide reasonable documentation confirming the donation. 
• Up to 14 days’ advance notice may be required. 

Important Notes: 

• This leave does not cover travel time or appointment scheduling. 
• Employees are protected from retaliation for requesting or using blood donation leave. 

Source: Oregon SB 1108 

Wage notice requirements at time of hire enacted 

Effective Date: January 1, 2026 

Oregon has enacted Senate Bill 906, introducing new wage notice requirements at the time of hire, effective January 1, 2026. These changes aim to enhance pay transparency and ensure employees understand their compensation structure from the outset. 

Employers must provide new hires with a written explanation of earnings and deductions that will appear on their itemized wage statement.  

Required Information Includes: 

• Pay Period Structure 
  • Employer’s established regular pay period. 
• Pay Rates and Compensation Types 
  • All types of pay rates the employee may be eligible for (e.g., hourly, salary, shift differentials, piece-rate, commission). 
• Deductions and Contributions 
  • Every deduction that could apply, with a description of its purpose. 
  • All benefit deductions and employer contributions. 
• Allowances 
  • Any allowances claimed as part of minimum wage. 
• Payroll Codes 
  • All codes used for pay rates and deductions, with definitions. 
• Employer-Provided Benefits 
  • Any benefits that may appear on pay stubs as contributions or deductions. 

Delivery Options: 

• Employers may provide this information: 
  • Electronically (email or secure portal) 
  • In hard copy 
  • Posted in a centralized, accessible location 

Annual Updates Required: 

• Employers must review and update the notice by January 1 each year to reflect any changes. 

Penalties for Non-Compliance: 

• Up to $500 per violation for failure to provide the required notice. 

People2.0 is compliant with these requirements. 

Source: California DIR FAQs 

Pennsylvania 

Paid Sick Days Act amended (Pittsburgh) 

Effective Date: January 1, 2026 

The City of Pittsburgh has amended its Paid Sick Days Act (PSDA), with the changes set to take effect on January 1, 2026. Here are the key updates:  

Key Changes to the PSDA: 

Increased Sick Leave Entitlement: 

• Employers with 15 or more employees must now provide 72 hours of paid sick leave annually. 
• Employers with fewer than 15 employees must provide 48 hours annually. 

Faster Accrual Rate: 

• Sick leave will accrue at a rate of 1 hour for every 30 hours worked, an increase from the previous rate of 1 hour per 35 hours. 

Carryover Provisions: 

• Unused sick time may be carried over to the following year unless the full annual amount is frontloaded at the beginning of the year. 

Who Is Covered: 

• This amendment applies to all employees working within Pittsburgh city limits, including those who work 35 or more hours annually in the city. 

Resource: Pittsburgh Paid Sick Days Act 

Ban-the-Box Ordinance amended (Philadelphia) 

Effective Date: January 1, 2026 

The City of Philadelphia has amended its Ban-the-Box Ordinance, formally known as the Fair Criminal Record Screening Standards Act. 

The ordinance now applies to all employers with at least one employee in Philadelphia (previously limited to employers with 10 or more employees). 

Stricter Criminal History Screening Rules 

Employers may not inquire about criminal history until after a conditional job offer is made. Additionally, the following are off-limits: 

• Arrests that did not lead to conviction 
• Summary offenses 
• Convictions older than seven years, excluding incarceration time 

Violations may result in fines up to $2,000 per incident and mandatory corrective actions enforced by the Philadelphia Commission on Human Relations (PCHR). Before taking adverse action based on a background check, employers must: 

• Provide a written notice 
• Share a copy of the background report 
• Allow the candidate time to respond 

Source: Philadelphia Press Release 

Rhode Island 

Temporary Caregiver Insurance program coverage expanded to include siblings 

Effective Date: January 1, 2026 

Starting January 1, 2026, Rhode Island will expand its Temporary Caregiver Insurance (TCI) program so that siblings can also qualify for caregiving leave. This update is part of a larger effort to enhance paid family leave benefits across the state. 

Key Highlights of the Update: 

• Expanded Family Definition: Employees will now be eligible to take TCI leave to care for a sibling with a serious health condition. Previously, the program only covered care for a child, parent, parent-in-law, grandparent, spouse, or domestic partner.  
• Effective Date: The sibling coverage begins January 1, 2026. 
• Leave Duration: The maximum duration of TCI leave will increase to 8 weeks starting in 2026. 

Job Protection: Employees taking TCI leave must be reinstated to their original or an equivalent position upon return. Employers must also maintain health benefits during the leave period. 

Source: Economic Progress Institute: Temporary Caregiver Insurance 

Written notice of employment information required 

Effective Date: January 1, 2026 

Effective January 1, 2026, Rhode Island law will require all employers to provide written notice to newly hired employees outlining specific employment terms and policies. This change is part of the state’s amendment to the Payment of Wages Law (House Bill 5679). 

Written Notice must include the following:  

• Employee’s Rate of pay and if it’s hourly, Salary or commission 
• Allowance claimed 
• Policies on paid time off, including:  
  • Sick Leave 
  • Vacation 
  • Personal leave 
  • Holidays 
• Employment Status 
• Deductions 
• Pay period details 
  • Number of days in the pay period 
  • Regular payday 
  • Date of first paycheck 
• Employer Information  
  • Legal name and any “doing business as” names 
  • Physical and mailing addresses 
  • Telephone number 

The law requires the notice to be in English and signed and dated by the employee. Employers are obligated to retain a copy for at least 3 years.  

People2.0 is in compliance with these requirements.  

Source: Rhode Island Legislature Press Release 

Texas

Nondisclosure and confidentiality provisions for sexual assault claims enacted 

Effective Date: September 1, 2025 

Texas Senate Bill 835, known as “Trey’s Law,” will go into effect on September 1, 2025, and introduces significant changes regarding nondisclosure and confidentiality agreements related to sexual abuse and assault. The bill aims to prevent the use of nondisclosure and confidentiality agreements that silence victims of sexual abuse or assault. 

Key Provisions: 

• Void and Unenforceable NDAs: Any nondisclosure or confidentiality provision in a contract, including settlement agreements that prohibits the disclosure of sexual abuse or sexual assault is rendered void and unenforceable  
• Retroactive Application: The law applies retroactively to agreements entered into before, on, or after the effective date, unless a court order specifically permits nondisclosure  
• Court Oversight: To enforce an NDA that conceals facts related to sexual abuse, a party must obtain a declaratory judgment and court order. 
• Limited Confidentiality Still Allowed: While facts or allegations of sexual abuse cannot be made confidential, parties may still agree to keep other terms of a settlement confidential such as payment amounts or unrelated provisions  
• No Private Right of Action: The law does not create a private cause of action, but it makes such confidentiality provisions unenforceable as a matter of law 

Source: Texas SB 835 Bill Text 

Healthcare non-compete reform enacted 

Effective Date: September 1, 2025 

Texas SB 1318 limits the enforceability of non-compete agreements for healthcare professionals in Texas. It expands protections beyond physicians to include dentists, nurses, and physician assistants, and sets clear boundaries on how non-competes can be structured. 

Key takeaways on changes:  

• Covered Roles: Applies to physicians, dentists, nurses, and physician assistants. 
• Buyout Cap: Any buyout must not exceed the employee’s annual salary and wages at the time of termination. 
• Geographic Limit: Restrictions must not exceed a 5-mile radius from the provider’s primary work location. 
• Duration Limit: Non-compete clauses may last no longer than one year after termination. 

Termination Without Good Cause: If a provider is terminated without good cause, the non-compete is automatically void. 

Source: Texas SB 1318 Bill Text 

Responsible Artificial Intelligence Governance Act enacted 

Effective Date: January 1, 2026 

The Texas Responsible Artificial Intelligence Governance Act (TRAIGA) was signed into law on June 22, 2025, and will take effect on January 1, 2026. This legislation establishes a statewide framework for the ethical development and deployment of artificial intelligence (AI) systems. 

Who must comply:  

• Developers: Entities that create or substantially modify high-risk AI systems. 
• Deployers: Entities that put AI systems into commercial use. 
• Digital Service Providers: Businesses that collect/process personal data via internet-connected platforms. 

1. Prohibited Uses of AI 

Developers and deployers must not intentionally design AI systems to: 

• Encourage self-harm, violence, or criminal activity 
• Discriminate against protected classes 
• Infringe on constitutional rights 
• Manipulate behavior in harmful ways 
• Generate or distribute illegal or sexually explicit content involving minors  

2. Transparency & Documentation 

Developers must maintain records detailing: 

• Purpose and intended use of the AI system 
• Types of data used for training 
• Outputs generated 
• Performance metrics and known limitations 
• Post-deployment monitoring and safeguards 

3. Consent & Data Use 

• Explicit user consent is required unless the data was publicly shared by the individual. 
• Developers must follow data possession and destruction rules. 

Enforcement & Safe Harbor 

• The Texas Attorney General has exclusive enforcement authority. 
• Developers have 60 days to cure violations after receiving notice. 
• Entities are not liable if they comply with recognized frameworks (e.g., NIST AI Risk Management Framework). 

Source: Texas HB 149 Bill Analysis 

Washington

Care program launched 

Effective Date: January 1, 2026 

Washington Care Program known as the Long-Term Services and Supports (LTSS) Trust Program is designed to help eligible Washington residents cover costs associated with long-term care needs, such as assistance with daily living activities due to aging, illness, or disability. This state-run initiative will begin providing benefits starting January 1, 2026. 

Contributions began on July 1, 2023, at a rate of 0.58% of wages. These are automatically deducted from employee paychecks unless an approved exemption is submitted. 

Benefit Availability: Up to $36,500 lifetime benefit, adjusted annually for inflation.  

Covered Services: In-home care, assisted living, adult day programs, home modifications, memory care, and more.  

Eligibility:  

Must have contributed to the program for 10 years (with no more than a 5-year break), or 

Paid in for 3 of the last 6 years and worked at least 500 hours per year. 

Must be a Washington resident and require assistance with at least three activities of daily living. 

Source: Washington RCW 50B.04.085 

Paid Family And Medical Leave Amendment enacted 

Effective Date: January 1, 2026 

House Bill (HB) 1213 extends access to job protection and other benefits under the state’s Paid Family and Medical Leave (PFML) program.  

What’s Changing? 

Currently, job protection under PFML is limited to employees who: 

• Work for employers with 50 or more employees. 
• Have been employed for at least 12 months. 
• Have worked 1,250 hours in the past year. 

Effective January 1, 2026, the updated law will: 

• Extend job protection to employees of businesses with 25 or more employees. 
• Require only 180 calendar days of employment with the employer. 
• Eliminate the 1,250-hour requirement, making protection more accessible. 

If the employees meet the updated eligibility criteria, their job will be protected while they take approved leave under PFML. This includes leave for: 

• Their own serious health condition. 
• Bonding with a new child. 
• Caring for a family member with a serious health condition. 
• Certain military-related events. 

Source: Washington Paid Leave Updates 

Leave and accommodation protections extended to hate crime victims 

Effective Date: January 1, 2026 

What’s Changing? 

Effective January 1, 2026, Washington State has expanded its Domestic Violence Leave Act to include employees who are victims of hate crimes, as well as those whose family or household members are victims. 

Leave Entitlement: Employees may take reasonable leave for: 

• Seeking legal or law enforcement assistance. 
• Obtaining medical or mental health treatment. 
• Accessing social services or counseling. 
• Safety planning or relocation. 

Accommodation Requirements: Employers must provide reasonable safety accommodations (e.g., modified schedules, workstation changes, security measures) unless doing so creates undue hardship. 

Anti-Retaliation Protections: Employers are prohibited from discriminating or retaliating against employees who request leave or accommodations under this law. 

Source: Washington HB 5101-S 

Looking ahead 

• Maryland paid family and medical leave — delayed to 2027 
• Illinois neonatal intensive care leave act enacted — effective June 1, 2026 
• Washington child labor laws amended — effective July 1, 2026 

Canada Updates 

Provincial Updates 

Alberta 

Minimum wage increase 

Effective Date: October 1, 2025 

Source: Bill 201 – Employment Standards Amendment Act 

Employment Standards (Protected Workers’ Pay) Amendment Act introduced 

This bill proposes: 

• Increasing Alberta’s minimum wage by $1 per year for three years, beginning December 2025 and reaching $18/hour by October 2027. 
• Indexing the minimum wage to the Consumer Price Index (CPI) thereafter so that wages grow with the cost of living.  
• Eliminating the youth minimum wage differential, which currently allows employers to pay students and youth under 18 as low as $13/hour.   
• Introducing tip protection provisions, ensuring gratuities go directly to the workers who earn them and prevent tip skimming from non-service staff. 

*These are proposals and are subject to change before or after Royal Assent, if enacted. 

Source: Bill 201 – Employment Standards Amendment Act 

British Columbia 

Minimum wage increase 

Effective Date: June 1, 2025 

On June 1, 2025, the British Columbia government raised the minimum wage from $17.40 to $17.85 an hour. 

Source: BC Minimum Wage Information 

Manitoba 

Minimum wage increase 

Effective Date: October 1, 2025 

On October 1, 2025, the Saskatchewan government raised the minimum wage from $15.80 to $16.00 an hour. 

New Brunswick 

Minimum wage increase 

Effective Date: April 1, 2025 

On April 1, 2025, the New Brunswick government raised the minimum wage from $15.30 to $15.65 an hour. 

Source: New Brunswick Minimum Wage Increase Announcement 

Newfoundland and Labrador 

Minimum wage increase 

Effective Date: April 1, 2025 

On April 1, 2025, the Newfoundland government raised the minimum wage from $15.60 to $16.00 an hour. 

Source: Newfoundland and Labrador Minimum Wage Announcement 

Labour Standards Act amended 

The Government of Newfoundland and Labrador has introduced several updates to the Labour Standards Act (LSA) through Bill 82 and Bill 101. These changes broaden employee leave entitlements and adjust employer obligations.  

1. Updates to Reservist Leave (Bill 82) 

Bill 82 expands and modernizes the province’s Reservist Leave provisions: 

• The definition of “service” now includes Canadian Forces military skills training, not just deployment-related training. 
• Eligibility has been reduced from 6 months to 3 months of civilian employment. 
• Reservists may now take up to 24 months of unpaid leave within a 60-month period (with no limits during a national emergency). 
• The required notice to take leave is reduced from 60 days to 30 days. 
• Changes to the expected return-to-work date must now be communicated at least 4 weeks in advance. 
• If adequate notice is not provided, employers may defer reinstatement for up to 4 weeks. 

2. New Long-Term Illness, Injury, and Organ Donation Leave (Bill 82) 

A new statutory leave has been introduced for employees needing extended medical care: 

• Employees with at least 30 days of service are entitled to up to 27 weeks of unpaid leave in a 52-week period. 
• A medical or nurse practitioner’s certificate is required, outlining the need for leave and the anticipated leave dates. 

3. Extended Leave for Long-Term Sick Leave Related to a Criminal Offence (Bill 82) 

Employees suffering a long-term illness or injury as a result of a criminal offence have expanded protections: 

• Entitlement to up to 104 weeks of unpaid leave. 
• Requires a medical certificate and acceptable proof that the injury/illness resulted from a criminal offence (provided the employee was not a party to the offence and did not contribute through gross negligence). 
• Employees are protected from dismissal for requesting or taking this leave and must be reinstated to terms no less favourable than before their leave. 

4. Removal of Medical Note Requirement for Sick Leave (Bill 101) 

• Employees are no longer required to provide a medical certificate for three or more consecutive days of statutory sick leave or family responsibility leave. 

Source: Littler: Newfoundland and Labrador Labour Standards Act Amendments 

Northwest Territories 

Minimum wage increase 

Effective Date: September 1, 2025 

On September 1, 2025, the Northwest Territory government raised the minimum wage from $16.70 to $16.95 an hour. 

Source: Northwest Territories Minimum Wage Increase Announcement 

Nova Scotia 

Minimum wage increase 

Effective Date: October 1, 2025 

On October 1, 2025, the Nova Scotia government raised the minimum wage from $15.70 to $16.50 an hour. 

Source: Nova Scotia Minimum Wage Increase Announcement 

Paid domestic violence leave expanded 

Effective Date: April 1, 2025 

Effective April 1, 2025, two additional days of paid leave will be added to the existing three days of paid domestic violence leave. 

Source: Nova Scotia Paid Domestic Violence Leave Information 

Helping Hardworking Nova Scotians Get Ahead Act introduced 

Proposed Labour Standards Code changes include: 

• Reducing the weekly hours required before overtime pay kicks in from 48 to 40 hours. 
• Overtime paid for work over 8 hours in a day. 
• A minimum 3-hour guarantee when an employee is required to report outside their scheduled hours. 
• Increasing the weekly rest period employees are guaranteed from 24 to 32 hours. 

*These are proposals and are subject to change before or after Royal Assent, if enacted. 

Source: Bill 169 – Helping Hardworking Nova Scotians Get Ahead Act 

Nunavut 

Minimum wage increase 

Effective Date: September 1, 2025 

On September 1, 2025, the Nunavut government raised the minimum wage from $19.00 to $19.75 an hour. 

Source: Nunavut Minimum Wage Increase Announcement 

Ontario 

Minimum wage increase 

Effective Date: October 1, 2025 

On October 1, 2025, the Ontario government raised the minimum wage from $17.20 to $17.60 an hour. 

Source: Ontario Minimum Wage Increase Announcement 

Public job posting and recordkeeping rules enacted 

Effective Date: July 1, 2025 and January 1, 2026 

These new requirements will come into effect in two phases: July 1, 2025, and January 1, 2026, and will apply to employers with 25 or more employees. 

Job Posting Requirements – Effective January 1, 2026 

New ESA requirements for publicly advertised job postings were introduced through the Working for Workers Four Act, 2024 and Working for Workers Five Act, 2024, and a recently published regulation provides important details regarding the scope of the new obligations. 

A publicly advertised job posting is defined as an external job posting that an employer or a person acting on behalf of an employer advertises to the general public in any manner, but does not include: 

• A general recruitment campaign that does not advertise a specific position; 
• A general help wanted sign that does not advertise a specific position; 
• A posting for a position that is restricted to existing employees of the employer; or 
• A posting for which work is to be (i) performed outside Ontario or (ii) performed outside Ontario and in Ontario and the work performed outside Ontario is not a continuation of work performed in Ontario. 

The following requirements apply to publicly advertised job postings: 

• Compensation range: An employer must include information about the expected compensation or the range of expected compensation for the position in the job posting. If a range is provided, the difference between the top and bottom compensation rates must not exceed $50,000 (e.g. $70,000 to $120,000). Compensation for the purposes of the job posting includes what would be considered “wages” as defined in section 1 of the ESA. Employers will have to carefully consider what compensation could be excluded from the range (if they so desire). 

This requirement does not apply where the job posting is for a position that has an expected annual compensation of more than $200,000 or where the position has a range of compensation that ends at an amount of more than $200,000. 

• Canadian experience: An employer must not include any requirements related to Canadian experience in the posting or application form. 
• Artificial intelligence: An employer who uses artificial intelligence to screen, assess or select applicants for the position must include a statement in the job posting disclosing the use of artificial intelligence. 

Artificial intelligence is defined as a machine-based system that, for explicit or implicit objectives, infers from the input it receives in order to generate outputs such as predictions, content, recommendations or decisions that can influence physical or virtual environments. 

• Existing vacancy: The job posting must include a statement disclosing whether the posting is for an existing vacancy or not. 
• Information after interview: If an employer interviews an applicant for a position in a job posting, the employer must, within 45 days after the date of the last interview, inform the employee of whether a hiring decision has been made in respect of the job posting. 
• Record retention: An employer must retain job postings and any associated application forms, as well as the information provided to applicants after an interview, for a period of three years. 

Employment Information for New Hires 

Requirements Effective July 1, 2025: 

Employers will be required to provide employees with the following information, in writing, before their first day of work, or if that is not practicable, as soon as reasonably possible: 

Employers will be required to provide employees with the following information, in writing, before their first day of work, or if that is not practicable, as soon as reasonably possible: 

• The legal name of the employer, as well as any operating or business name of the employer if different from the legal name; 
• Contact information for the employer, including address, telephone number and one or more contact names; 
• A general description of where it is anticipated that the employee will initially perform work; 
• The employee’s starting hourly or other wage rate or commission, as applicable; 
• The pay period and pay day established by the employer; and 
• A general description of the employee’s initial anticipated hours of work. 

The employment information requirements do not apply to the following: 

• employers with less than twenty-five (25) employees on the employee’s first day of work; or 
• an employee who is an assignment employee. 

For greater clarity, “assignment employees” are defined in the ESA as an employee employed by a temporary help agency for the purpose of being assigned to perform work on a temporary basis for clients of the agency. 

Working for Workers Seven Act, 2025 (Bill 30) receives Royal Assent

On November 27, 2025, Ontario’s Working for Workers Seven Act, 2025 (Bill 30) received Royal Assent.  

Changes include: 

• Job Posting Platform Requirements (in force on January 1, 2026) 
  • Requiring job-posting platforms to have a mechanism for reporting fraudulent job ads. 
  • Mandate written policies addressing fraudulent job postings, including procedures for handling such reports. 
  • Require platforms to display reporting mechanisms conspicuously and post their fraud policies where users can readily access them. 
  • Establish record retention requirements for fraud policies (three years after the applicable policy ceases to be in effect) 
• Job Seeking Leave (now in force) 
  • Establish a new unpaid leave entitlement for employees who receive a notice of termination in cases where 50 or more employees are being terminated. 
  • Allow up to three days of unpaid leave during the notice period for job-seeking purposes, including interviews, searching for employment, and participating in training. 
  • Require employees to provide a minimum of three days’ advance notice when possible. 
  • Permit employers to request documentation substantiating entitlement and consider partial days as full days of leave. 
  • Exclude employees from this entitlement if they receive pay in lieu of notice equivalent to 25% or less of the required notice period. 
• Extended Layoff Provisions (now in force) 
  • Permit extended layoffs of non-unionized employees, up to 52 weeks in a consecutive 78-week period and subject to specific conditions. 
  • Require mutual agreement to an extended layoff (i.e. any layoff in excess of 35 weeks in a consecutive 52-week period) between employer and employee, plus Director of Employment Standards approval. 
  • Mandate written agreements specifying the latest date the employer intends to recall the employee, which cannot be withdrawn by the employee once entered into. 
  • Establish application and approval processes through the Director. 
  • Require employers to retain copies of extended layoff agreements for three years after approval expiry. 
  • Establish rules for determining whether an employee who does not have a regular work week is laid off for an extended period. 
• Enhancing penalties under the Workplace Safety and Insurance Act (WSIA) – including higher fines and additional “aggravating factors” for employer non-compliance 

Source: Hicks Morley: Working for Workers Seven Act Analysis 

Prince Edward Island 

Minimum wage increase 

Effective Date: October 1, 2025 

On October 1, 2025, the Prince Edward Island government raised the minimum wage from $16.00 to $16.50 an hour. 

Source: Prince Edward Island Minimum Wage Increase Announcement 

Quebec 

Minimum wage increase 

Effective Date: May 1, 2025 

On May 1, 2025, the Quebec government raised the minimum wage from $15.75 to $16.10 an hour. 

For tip receiving workers, the minimum went from $12.60 to $12.90 an hour. 

Source: CNESST Wage and Pay Information 

Francization requirements expanded 

Effective Date: June 1, 2025 

Effective June 1, 2025, businesses with at least 25 employees in Quebec for a minimum of six months must comply with the Charter of the French Language. This lowers the previous threshold from 50 employees. Impacted companies are required to register with the Office québécois de la langue française, assess their linguistic practices, and, if necessary, implement a francization program. 

Source: AWCBC: Quebec Employment and Labour Law Changes 

Saskatchewan 

Minimum wage increase 

Effective Date: October 1, 2025 

On October 1, 2025, the Saskatchewan government raised the minimum wage from $15.00 to $15.35 an hour. 

Source: Saskatchewan Minimum Wage Increase Announcement 

Employment Act amendments enacted 

Effective Date: January 1, 2026 

• Medical Note Requests: 
  Employers will now be limited in when they can request a medical certificate for employee absences due to illness or injury (whether the employee’s own or that of an immediate family member). A request may only be made if: 
  • The employee has been absent for more than five consecutive working days, or 
  • The employee has had two or more non-consecutive absences within the preceding 12 months. 
• Extended Sick Leave Entitlements: 
  Employees will now have access to up to 27 weeks of unpaid, job-protected long-term sick leave, up from the previous 12 weeks. This aligns provincial job protection provisions with federal Employment Insurance (EI) sickness benefits. 
• Expanded Bereavement Leave: 
  The legislation clarifies that bereavement leave can now be taken in the event of a pregnancy loss. It also extends the time frame within which employees can take their five days of unpaid bereavement leave to within six months of the death or pregnancy loss, providing greater flexibility for affected employees. 
• Maternity Leave Changes: 
  Maternity leave entitlement has been expanded to cover employees who experience a pregnancy loss up to 20 weeks before the estimated due date. 
• New Interpersonal Violence Leave: 
  Employees experiencing interpersonal or sexual violence will now be entitled to a new unpaid leave of up to 16 weeks, to be taken in one continuous period within a 52-week timeframe. This is in addition to the existing entitlement of 10 days (five paid and five unpaid), which may be taken consecutively or intermittently. Leave may be used for purposes such as accessing medical or counseling services, relocating, or seeking legal or law enforcement assistance. 
• Gratuity (Tips) Protections: 
  Employers will be prohibited from withholding, deducting, or requiring the return of tips or gratuities, unless expressly permitted by law. The amendments also provide regulatory authority to define “gratuities” and set conditions for permissible tip pooling arrangements. Specific regulatory details are pending at this time. 
• Flexible Definition of Overtime ‘Day’: 
  Employers may now define a “workday” for overtime purposes as either a calendar day or a 24-consecutive-hour period. Regardless of the definition chosen, employees must still receive at least eight consecutive hours of rest in any 24-hour period. Employers must clearly communicate their chosen definition to employees when providing work schedules. 

Other Notable Changes 

• Wage Payment Clarifications: 
  Employers may pay wages in cash, and are not required to pay vacation pay on periods covered by statutory pay in lieu of notice. 
• Part-Time Overtime Rules: 
  Part-time employees will now have overtime calculated based on their scheduled hours, rather than the default eight-hour workday. 
• Variances for Non-Union Workplaces: 
  Non-unionized employers may apply to the Director of Employment Standards for variances to meal break and scheduling notice requirements, provided they have written employee consent. Unions may also negotiate similar variances directly with employers. 
• Retail Employee Rest Periods: 
  The requirement for two consecutive days off per week for retail workers has been revised to one day off per week, aligning this industry with other sectors. 
• Permissible Payroll Deductions: 
  With employee consent, employers may now deduct amounts for salary advances, voluntary training, and housing allowances from wages. 
• Enhanced Enforcement for Discriminatory Actions: 
  The Director of Employment Standards will have expanded authority to order remedies if an employer takes discriminatory action against an employee, including: 
  • Reinstatement of the employee 
  • Payment of lost wages 
  • Removal of disciplinary records 
    These orders are immediately enforceable, even if under appeal, unless set aside by an adjudicator or the Director. 
• Mass Termination Notification Threshold Raised: 
  Employers will now be required to notify affected employees, the Minister, and any relevant union when terminating 25 or more employees within a four-week period. Previously, the threshold was 10 employees. 

Source: MLT Aikins: Saskatchewan Employment Act Amendments 

Yukon 

Minimum wage increase 

Effective Date: April 1, 2025 

On April 1, 2025, the Yukon government raised the minimum wage from $17.59 to $17.94 an hour. 

Source: Yukon Minimum Wage Increase Announcement 

For questions about how these changes may affect your operations, please contact your local People2.0 representative or the Human Resources team. For the US HR team you may contact HR@People20.com and Canada HR team at hrcanada@people20.com. 

DISCLAIMER 

The information provided in this alert does not, and is not intended to, constitute legal advice; rather, all information, content, and materials available on this site are for general informational purposes only. Information on this update is not intended to be comprehensive and may not constitute the most up-to-date legal or other information. This update contains links to other third-party websites. Such links are only for the convenience of the reader, user, or browser; People2.0 does not recommend or endorse the contents of the third-party sites. People2.0 bears no responsibility for the accuracy, legality or content of the external site or for that of subsequent links. 

Readers of this update should contact their attorney to obtain advice with respect to any particular legal matter. No reader, user, or browser of this update should act or refrain from acting on the basis of information herein without first seeking legal advice from counsel in the relevant jurisdiction. Only your individual attorney can provide assurances that the information contained herein — and your interpretation of it — is applicable or appropriate to your particular situation. Use of, and access to, this update or any of the links or resources contained within do not create an attorney-client relationship between the reader, user, or browser and People2.0.