Employer Compliance Watchlist: Key State Laws Effective January 1, 2026

Quick Hits

• Several new state laws that took effect January 1, 2026, significantly impact employer compliance in areas such as wage and hour regulations, leave administration, and workplace notices, requiring multistate employers to update policies and procedures accordingly.
• Notable changes include California’s expansion of leave protections for crime victims and the introduction of the mini-WARN Act, Illinois’s new human rights protections for artificial intelligence, and Pennsylvania’s CROWN Act.

California

Crime Victim Leave and Paid Sick Leave—Assembly Bill (AB) 406

On October 1, 2025, Governor Gavin Newsom signed AB 406, expanding leave protection for employees who are victims of violence or when their family members are victims to seek legal, medical, mental health, or safety planning services. The law requires employers with twenty-five or more employees to provide leave for covered activities subject to reasonable notice and certification. It does not mandate paid leave, but employees may use available paid sick leave or other accrued paid time off (PTO). The law also expands the covered reasons for using paid sick leave to include leave to appear as a witness and for jury duty. The law took effect on January 1, 2026.

Family and Medical Leave—Senate Bill (SB) 590

Governor Newsom signed SB 590 on October 13, 2025. The law expands eligibility for paid family and medical leave to individuals who take time off work to care for a seriously ill “designated person,” meaning “any care recipient related by blood or whose association with the individual is the equivalent of a family relationship.”

Mini-WARN Act—SB 617

SB 617, signed on October 1, 2025, expands the notice content requirements under the California Worker Adjustment and Retraining Notification (Cal-WARN) Act to require employers to include additional information in their notices of mass layoffs, terminations, or relocations. Under the law, employers must disclose whether they plan to coordinate services, such as a rapid response orientation, through the local workforce development board or another entity, and include specific contact information and descriptions of available services.

Required Employer Postings—SB 294

Governor Newsom signed SB 294, the “Workplace Know Your Rights Act,” on October 12, 2025, to require employers “provide a stand-alone written notice” to each employee addressing independent contractor misclassification protections, heat illness prevention, workers’ compensation, paid sick days, protections against unfair immigration-related practices, the right to notice of federal immigration inspections, the right to organize a union in the workplace, and constitutional rights when interacting with law enforcement at the workplace. Employers have until February 1, 2026, to make the posting, but the Labor Commission has released a template notice that complies with the law.

Stay or Pay Clauses—AB 692

Governor Newsom signed AB 692 on October 13, 2025, banning employers from inserting into employment contracts clauses that require workers to repay the employer, training provider, or debt collector for training costs after employment ends, often referred to as “stay or pay” clauses. The law does not apply to retention bonuses and certain loans if specific conditions are met.

Additional updates on new California laws can be found here.

Colorado

Paid Family and Medical Leave—SB 25-144

On May 30, 2025, Governor Jared Polis signed legislation expanding the state’s Family and Medical Leave Insurance (FAMLI) program to provide up to twelve weeks of paid leave for parents with a child in a neonatal intensive care unit (NICU). It took effect on January 1, 2026. In addition, the legislation reduces FAMLI premiums for 2026 from 0.9 percent of an employee’s wages to 0.88 percent for 2026 with premiums from 2027 and on to be set annually.

Connecticut

Family and Medical Leave Benefit Increase

Effective January 1, 2026, due to the increase in the state’s minimum wage for 2026, the maximum weekly paid family and medical leave benefit amount available under the Connecticut Paid Leave program increases to $1,016.40, which is capped at sixty times the state minimum wage rate. The employee contribution rate for 2026 remains at 0.5 percent, unchanged from the 2025 rate.

Paid Sick Leave—Public Act (PA) No. 24-8

Under amendments to Connecticut’s paid sick leave program in PA 24-8, enacted in 2024, paid sick leave requirements cover smaller employers. As of January 1, 2026, employers with eleven or more employees (a decrease from at least twenty-five employees) are required to accrue paid sick leave.

Delaware

Family and Medical Leave—HB 128

Beginning on January 1, 2026, employees may take up to twelve weeks of paid leave per year to care for a new child, or six weeks of paid leave per year to address a serious health condition or care for a family member with a serious medical condition, under the Healthy Delaware Families Act. The state’s paid family and medical leave (PFML) law has also been amended to prohibit employers from requiring an employee to use accrued paid time off (PTO) before accessing PFML benefits, among other changes.

Illinois

Artificial Intelligence and Human Rights—HB 3773

On August 9, 2024, Governor JB Pritzker signed HB 3773 into law, amending the Illinois Human Rights Act (IHRA) to make it a civil rights violation to use artificial intelligence in ways that result in unlawful discrimination in employment decisions, including hiring, promotions, and discipline, even if such discrimination is unintentional. The law also addresses the use of zip codes as a proxy for protected classes, recognizing the potential for such practices to lead to discriminatory outcomes. The law took effect on January 1, 2026. In late 2026, the Illinois Human Rights Department shared draft (non-final) rules clarifying the notice and recordkeeping requirements for employers regarding the use of AI in making employment decisions.

Employee-Provided Devices Use—HB 1278

Effective January 1, 2026, the Illinois Victims’ Economic Security and Safety Act prohibits employers from discharging, refusing to hire, or discriminating or retaliating against employees because they used employer-issued electronic equipment to record a crime of violence, including domestic violence and sexual violence, committed against them, a member of their family, or their household member. The law also prohibits employers from depriving an employee of a device because the employee used it to record such incidents and requires employers to provide an employee or, a family member if the employee is incapacitated, access to any photographs or recordings of such incidents from an employer-issued device.

Wage Garnishments—SB 1738

Effective January 1, 2026, SB 1738, which Governor Pritzker signed on August 1, 2025, entitles a debtor-employee to a $1,000 automatic exemption where a consumer debt judgment has been entered against the debtor-employee, applying to judgments entered on or after January 1, 2020.

Medical Donation Leave— HB 1616 

Effective January 1, 2026, the Illinois Employee Blood and Organ Donation Leave Act is amended to allow part-time employees to take leave for organ donation. Previously, Illinois law only provided organ donation leave time to full-time employees.

Paid Lactation Breaks—SB 212

On August 1, 2025, Illinois amended the Nursing Mothers in the Workplace Act to make it clear that breaks for employees to express breast milk for a nursing infant be paid at the employee’s regular rate of pay and employees cannot be required to use paid leave. The amendments take effect January 1, 2026.

Additional updates on new Illinois laws can be found here.

Massachusetts

Family and Medical Leave

The Massachusetts Department of Family and Medical Leave (DFML) announced on October 1, 2025, that the maximum paid family and medical leave (PFML) weekly benefit amount increases to $1,230.39 in 2026, representing a $60 increase from 2025. The employer and employee contribution rates for 2026 remain unchanged from those in 2025. The 2026 DFML workplace poster template can be found on the department’s website.

Minnesota

Family and Medical Leave

On January 1, 2026, the Minnesota Paid Leave law took effect, providing qualified employees up to twelve weeks of paid medical leave or paid family leave. Employees who need both in a single benefit year may qualify for up to twenty weeks. Employers had until December 1, 2025, to notify employees about their rights and benefits under the new law.

Meal and Rest Breaks—Senate File (SF) 17 / House File (HF) 15

Starting January 1, 2026, employers in Minnesota must provide employees working six or more consecutive hours with a thirty-minute unpaid meal break and a fifteen-minute paid rest break. In September 2025, the Minnesota Department of Labor and Industry published guidance on the upcoming changes to meal and rest breaks.

Paid Sick Leave—SF17 / HF15

SF17 / HF15 further amended the Minnesota Earned Sick and Safe Time (ESST) to allow employers to set reasonable notice requirements for unforeseeable leave and to require documentation for leave taken for two consecutive workdays.

Montana

Restrictive Covenants—HB 620

Effective January 1, 2026, Montana’s HB 620 expands the ban on noncompetes in healthcare to licensed physicians of all specialties.

Nevada

Workplace Safety Wildfire Smoke—SB 260

On June 10, 2025, Governor Joe Lombardo signed SB 260, expanding workplace safety protections. Employers with ten or more employees (with certain industry exceptions) need to monitor air quality and reduce their employees’ exposure to wildfire smoke. Certain provisions of the bill apply only to employers whose employees perform “critical tasks outdoors.”

New Hampshire

Family and Medical Leave—HB 2

Effective January 1, 2026, covered New Hampshire employers are required to provide leave for an employee’s own medical appointments for childbirth, an employee’s postpartum care, and an infant’s pediatric medical appointments.

Military Leave—HB 225

HB 225, signed into law in July 2025, requires employers with fifty or more employees at a single location in New Hampshire to provide job protections for the spouses of military service members who have been involuntarily mobilized for military service beginning January 1, 2026. The law expands on the protections provided by the Uniformed Services Employment and Reemployment Rights Act (USERRA), which provides job protections for service members themselves.

New York

Family and Medical

New York’s Paid Family Leave (PFL) program has announced updates for 2026, including increases in the maximum weekly PFL benefit amount and the employee contribution rate, effective January 1, 2026.

New York City Paid Sick Leave— Int. No. 0780-2024

In October 2025, New York City enacted amendments to the city’s Earned Safe and Sick Time Act (ESSTA) to expand covered reasons to take earned safe and sick time and add a separate bank of thirty-two hours of unpaid earned safe and sick time in addition to the forty or fifty-six hours already provided under the ESSTA. The law took effect on February 22, 2026.

Oregon

Medical Debt Reporting—SB 0605

On June 17, 2025, Governor Tina Kotek signed SB 0605 into law, banning the reporting of medical debt owed by Oregon residents to consumer reporting agencies. The law took effect on January 1, 2026.

Blood Donation Leave—SB 1108

SB 1108, signed on May 28, 2025, expands Oregon’s paid sick leave law to allow employees to take paid leave to donate blood as part of a voluntary donation program approved or accredited by the American Association of Blood Banks or the American Red Cross. The law took effect January 1, 2026.

Unemployment Benefits During Labor Disputes—SB 916

Oregon eliminated the labor dispute disqualification from the state’s unemployment insurance. Beginning January 4, 2026, striking and locked-out workers may qualify for unemployment benefits for up to ten weeks.

Hiring Notices—SB 906

After signing a bill in mid-2025 that restricted age-based inquiries during hiring, Governor Kotek also signed into law a bill that amends Oregon’s current state payroll law. The bill, which took effect on January 1, 2026, requires employers to disclose information about payroll practices to new employees upon their hire.

Pennsylvania

CROWN Act—HB 439

Governor Josh Shapiro signed the Creating a Respectful and Open World for Natural Hair (CROWN) Act into law on November 25, 2025, prohibiting discrimination based on employees’ hairstyles associated with race. The law broadens the definition of “race” under the Pennsylvania Human Relations Act to include traits such as hair texture and protective hairstyles. The law makes Pennsylvania the twenty-eighth state to prohibit race-based hair discrimination. The law goes into effect on January 24, 2026.

Rhode Island

Paid Family and Medical Leave—HB 6066

HB 6066 amends Rhode Island’s Temporary Caregiver Insurance (TCI) program to add employees’ siblings as covered family members, effective January 1, 2026, Additionally, TCI leave benefits for 2026 increases from seven to eight weeks per year.

Medical Donation Leave—SB 0829 A

Effective January 1, 2026, Rhode Island’s Temporary Caregiver Insurance program covers leave for bone marrow donation and organ donation.

Wage Notice Upon Hire—S 0070 A

Effective January 1, 2026, S 0070 A requires Rhode Island employers to provide employees upon hire a written notice containing the employee’s wage rate, the length of the pay periods, paydays, and certain other wage- and employment-related information.

Washington

Crime Victim Leave—SB 5101

Effective January 1, 2026, Washington SB 5101 amended the state’s Domestic Violence Leave Law, which already applies to employees who are victims of domestic violence, sexual assault, and stalking, to provide leave and safety accommodations to employees who are victims of hate crimes or have a family member who is a victim of a hate crime.

Family and Medical Leave—HB 1213

Signed on May 17, 2025, HB 1213 amends the PFML law, expanding the job protection provisions. The amendments take effect on January 1, 2026.

Additionally, on October 29, 2025, Washington’s Employment Security Department announced an increase in the paid family and medical leave (PFML) premium rate for 2026. The maximum weekly PFML benefit amount is also set to increase in 2026.

Benefits During Labor Disputes—SB 5041

Under Washington’s SB 5041, striking and locked-out workers may qualify for unemployment benefits, if they are otherwise eligible. Washington is limiting benefits of up to six weeks.

Workplace Safety Isolated Employees—HB 1524

Washington is also expanding its safety standards for “isolated” employees as of January 1, 2026. The new standards apply to hotels, motels, retail, security guard entities, and property services contractors. The updates expand the definition of “isolated employee” and adds training, recordkeeping, and other requirements such as panic buttons.

Workplace Violence Prevention—HB 1162

HB 1162 makes minor changes to the process healthcare employers must follow in developing and updating their workplace violence prevention plans. The law was enacted on May 17, 2025, and took effect on January 1, 2026.

Prevailing Wage Construction Projects—HB 2136

Through HB 2136, a law signed by former Governor Jay Inslee, which delayed the effective date to January 1, 2026, Washington ramped up enforcement of employers that fail to comply with the state’s prevailing wage law on public construction projects.

Next Steps

Multistate employers may want to note the many new laws that took effect January 1, 2026, and may want to review and update policies, handbooks, job postings, payroll systems, and onboarding documentation to align with the following developments.

Ogletree Deakins’ Multistate Advice and Counseling Practice Group will continue to monitor developments and will provide updates on the Background Checks, Cybersecurity and Privacy, Drug Testing, Employment Law, Healthcare, Leaves of Absence, Multistate Compliance, Pay Equity, Reductions in Force, State Developments, Technology, Unfair Competition and Trade Secrets, Wage and Hour, Workplace Safety and Health, and Workplace Violence Prevention blogs.

In addition, the Ogletree Deakins Client Portal tracks developments and provides real-time updates on state employment laws. (Full law summaries and template policies are available for Premium-level subscribers; Snapshots and Updates are available for all registered client-users.) For more information on the Client Portal or a Client Portal subscription, please reach out to clientportal@ogletree.com.

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