Connecticut Expands Paid Sick Law to Establish Entitlements for Most Employees by 2027

Below is an overview of the current law and the expansion via Public Act No. 24-8.

	Current Law	Expansion Under Public Act No. 24-8 Effective January 1, 2025 (Unless Otherwise Noted)
Covered Employees	The current law applies to “service workers,” who are defined as employees in certain occupations identified in the U.S Bureau of Labor Statistics’ Standard Occupational Classification system.	The expanded law applies to all employees, excluding seasonal employees who work 120 days or fewer during a year.
Covered Employers	The current law applies to employers with 50 or more service workers. The service worker threshold is determined by the company’s payroll for the week containing October 1.	Effective January 1, 2025: Employers with 25 or more employees Effective January 1, 2026: Employers with 11 or more employees Effective January 1, 2027: Employers with 1 or more employees The employee threshold is determined by a company’s payroll for the week containing January 1.
Excluded Employers	The current law excludes certain manufacturing employers and nationally chartered nonprofits.	The new law no longer contains an exclusion for certain manufactures and nationally charted nonprofits. The new law excludes an employer that participates in a multiemployer health plan that is maintained pursuant to a collective bargaining agreement between a construction-related union and employer. Self-employed individuals are also excluded.
Transferred Employees and Successor Employers		New: An employer must allow an employee to retain his/her accrued sick leave if transferred within the company or if another employer succeeds or takes the place of the existing employer.
Employee Eligibility	Service workers may not use accrued sick time until they have worked 680 hours.	Under the expanded law, employees may use accrued sick time on and after 120 calendar days of employment.
Accrual (General)	Accrual of paid sick time begins upon hire at a rate of 1 hour of sick time for every 40 hours worked, up to a maximum of 40 hours per year.	Accrual of paid sick time still begins upon hire, except it accrues at a rate of 1 hour of sick time for every 30 hours worked, up to a maximum of 40 hours per year.
Accrual (Exempt Employees)		New: The law presumes that exempt employees work 40 hours per week for the purposes of sick time accrual.
Carryover	Service workers are entitled to carry over up to 40 hours of sick time from the current year to the following year.	No change. However, in lieu of carryover, employers may front-load sick time that meets or exceeds the requirements of the law.
Finding Replacements to Cover Shifts		New: An employer may not require an employee to find coverage for his/her shift.
Reasons for Leave	Reasons for leave cover the service worker’s need for leave, as well as the service worker’s children and spouse. A service worker may use sick time for: 1. the service worker’s or spouse’s/child’s illness, injury, or health condition; 2. the medical diagnosis, care or treatment of service worker’s or spouse’s/child’s mental or physical illness, injury, or health condition; 3. preventative medical care for the service worker or the service worker’s spouse or child; 4. the service worker’s mental health wellness day; and 5. for certain circumstances where the service worker or the service worker’s child is a victim of family violence or sexual assault, provided that the service worker is not the alleged perpetrator.	Expands the use of sick time to include “family members,” a definition that (like Connecticut’s Family and Medical Leave Act) encompasses spouses, siblings, children, grandparents, grandchildren, and parents, as well as individuals who are “related to the employee by blood or affinity whose close association the employee shows to be equivalent to those family relationships.” An employee may use sick time for: 1. the employee’s or the employee’s family member’s illness, injury, or health condition; 2. the medical diagnosis, care, or treatment of the employee’s or family member’s mental or physical illness, injury, or health condition; 3. preventive medical care for the employee’s or family member’s mental or physical health; 4. the employee’s mental health wellness day; 5. for certain circumstances where the employee or family member is a victim of family violence or sexual assault, provided that the employee is not the alleged perpetrator; 6. closure by order of a public official, due to a public health emergency, of either (a) an employer’s place of business or (b) a family member’s school or place of care; 7. a determination by a health authority, employer of the employee, employer of a family member, or a healthcare provider that an employee or employee’s family member poses a risk to the health of others due to an exposure to a communicable illness, whether or not the employee or family member contracted the communicable illness.
Employee Notice and Documentation	Employers may require a maximum of 7 days’ notice if the service worker’s need to use paid sick time is foreseeable.   Employers may only request reasonable documentation if the service worker uses paid sick time for 3 or more consecutive workday absences.	The expanded law removes foreseeable notice and documentation requirements. An employer may not require an employee to provide documentation that leave is being taken for a permitted purpose.
Employer Notice to Employees	Employers must provide notice to each service worker of his or her rights under the law at the time of hire.   Employers may comply with the notice requirement by displaying a poster in a conspicuous place, accessible to service workers, at the employer’s place of business that contains the information required by the law in both English and Spanish.	Employers must (1) display a poster in a conspicuous place accessible to employees; and (2) provide written notice to employees by January 1, 2025, or at the time or hire, whichever is later. The Connecticut Department of Labor (CTDOL) will create a model poster for employers.
Records Retention		New: An employer must retain sick time records for a period of three years, including: (1) the number of hours of paid sick time accrued or provided to the employee; and (2) the number of hours used by the employee during the calendar year. CTDOL may inspect the sick time records and assess penalties for failure to keep required records.

On May 9, 2024, the legislature transmitted the bill to Governor Ned Lamont, who is expected to sign it. Prior to January 1, 2025, employers may want to review their sick time and paid time off (PTO) policies for compliance and prepare to provide notice to employees.

Ogletree Deakins’ Stamford office will continue to monitor developments and will provide updates on the Connecticut and Leaves of Absence blogs as additional information becomes available.

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