CT Paid Sick Leave Expansion: HR Guide to Compliance (2025)

CT Paid Leave: New Requirement for Private Employers Starting in 2027

Connecticut’s paid leave program is evolving, and starting in 2027, private employers will be subject to new requirements. This is on top of the significant expansion that began on Jan. 1, 2025, with new accrual rates, eligible employees, permissible uses, and employer obligations.

This guide reviews the existing paid leave program, the upcoming changes, and what businesses need to know to manage state compliance.

What Is Connecticut’s Current Paid Leave Program?

Connecticut’s Paid Leave Program (CTPL) launched in 2021, offering employees paid leave for qualifying family and medical reasons. The program is funded by employee payroll deductions, providing wage replacement for various qualifying reasons.

There is a significant overlap between the Family and Medical Leave Act (FMLA) and the Connecticut Paid Sick Leave Law. Employers and employees need to be on the same page regarding which type of leave an employee wants to use and if they intend to split their leave between paid CTPL time and unpaid FMLA time.

Personal Health Conditions

Employees can use paid leave for mental or physical health conditions that render them unable to work. Preventive medical care and medical diagnosis are important parts of paid leave, as Connecticut employees are more likely to schedule check ups with paid leave available.

Public Health Emergencies

When an employee’s workplace or a family member’s school/place of care is closed due to a public health emergency, they can use Connecticut paid leave.

Mental Health Wellness Days

Employees can use Connecticut paid leave for mental health days, prioritizing their wellness and managing the effects of stress rather than attempting to cope in the workplace.

Safe Leave

Employees can use paid leave if they’re a victim of family violence or sexual assault. This includes leave relating to legal, medical, and mental health appointments resulting from the incident.

Caring for a Family Member

Leave covers care for an employee’s family member with a serious health condition. The term “family member” includes not only immediate family but also those with equivalent family relationships, such as in-laws, grandparents, and others considered family by the worker. Employees can also designate unofficial family members, like close family friends.

Parental Leave

New parents can take leave to bond with a newborn, adopted, or foster child.

Military Family Leave

Employees can take leave to manage situations related to family members’ military service.

The Connecticut Paid Leave Authority manages the CTPL program, ensuring employees have access to wage replacement for up to 12 weeks (with an additional two weeks for pregnancy complications). The program’s wage replacement is capped at 60 times the minimum wage, allowing employees to receive a substantial portion of their income while on leave.

Which Employers Are Covered by the Connecticut Paid Leave Law?

The current paid leave law only applies to larger employers in specific industries, but it is changing to encompass employers of every size within nearly every industry. This expansion will occur incrementally over the course of several years.

The upcoming program applies to employers with one or more employees in the state, covering almost all private employers in Connecticut. The most significant exemptions are certain nonprofits, federal employees, and municipalities unless they opt in.

Contributions to the program come from employee payroll deductions, and employers are not required to make a direct contribution. A 0.5% deduction must be taken from employee payroll and remitted to the program.

What Are the New Requirements for Connecticut’s Paid Leave Program?

Connecticut’s Paid Leave Program will expand its requirements starting in 2025, particularly for private employers. After that, the paid leave program will be implemented at different times for employers of different sizes.

The plan will be rolled out in three phases. On Jan. 1, 2025, the new law will apply to employers with at least 25 employees. On Jan. 1, 2026, the law will apply to employers with at least 11 employees, and as of Jan. 1, 2027, the law will apply to all employers regardless of total employee count.

Expanded Definition of Covered Employees

Currently, only employers in certain industries (like service workers) must provide paid sick leave. In 2027, this will expand to all private employers, regardless of size or industry.

The limited exceptions include:

Seasonal Employees: Those working 120 days or less per year.
Unionized Employees: Connecticut has the highest percentage of unionized workers in the country. Unionized workers covered under a collective bargaining agreement tied to a multiemployer health plan are exempt.
Self-Employed Individuals: Independent contractors remain exempt.

Sick Leave Accrual, Carryover, and Frontloading

Since Jan. 1, 2025, the accrual rate is one hour for every 30 hours worked. The leave accrual cap is up to 40 hours per year. Employees become eligible to use accrued sick leave after 120 calendar days of employment.

Employees can carry over up to 40 unused hours into the next calendar year. Additionally, employers can frontload 40 hours of sick leave at the beginning of the year. If you’re frontloading, carryover is not required.

Employers must decide whether to implement accrual-based or frontloaded leave policies, balancing administrative ease with employee flexibility. Note that employers aren’t currently required to pay out accrued sick leave upon termination of an employee, so payouts should not play a role in your decision.

Sick Leave Accrual and Usage

Under the current program, employees accrue one hour of paid leave for every 40 hours worked. The new requirement reduces the accrual rate to one hour of paid leave for every 30 hours worked. Employees can accrue a maximum of 40 paid leave hours per year, which will remain the same.

Up to the full 40 hours accrued can be carried over into the following year, but an employee cannot use more than 40 hours of paid leave in a single year. The benefit of accrual and carryover won’t extend an employee’s maximum leave time, but it can help them use their full 40 hours at the beginning of the year (in the form of last year’s accrued hours).

Do Employers Make Contributions to Paid Leave?

Paid leave is entirely employee-funded; employers aren’t expected to contribute to the program. However, employers who wish to offer paid leave programs voluntarily can contribute to employee-paid leave funds. Employers can use these independent paid leave systems if they meet or exceed the state’s specified requirements.

How To Prepare for Compliance Changes in 2027

Preparing for Connecticut’s 2027 paid leave changes requires careful planning and action. Employers must focus on updating policies, improving payroll systems, and ensuring clear communication with employees.

Many employers are expected to comply by Jan. 1, 2025, rather than the final 2027 due date for the smallest Connecticut businesses.

Remember, there is no penalty for early compliance, but there will be penalties for failing to comply by the due date for your organization’s size. If your organization has less than 25 employees, it may be wise to implement a compliance strategy to roll out as soon as possible.

Update Paid Leave Policies

If your organization doesn’t already offer paid sick leave and was not previously required to do so, now is the time to start developing a comprehensive policy.

Employers should create or revise existing leave policies to meet state-mandated accrual rates and outline how employees can use sick time. Make sure your policy covers all employees, taking into account the expanded eligibility under the 2027 amendments.

Define what situations qualify for paid sick leave, including personal illness, family caregiving, or preventive care. You can provide sick leave for more reasons than is listed by the new paid leave act, but you can’t remove or modify the provisions as they exist within the law.

An employee handbook can serve as a centralized resource related to paid leave policies, and Employee Handbooks by Mosey make building one hassle-free. One-click policy updates streamline handbook maintenance as employment laws change, while our user-friendly employee portal ensures your workers stay up to date.

Implement or Enhance Payroll Systems

Employers will need an efficient system to track sick leave accrual and usage. Many companies already have one in place for other forms of paid leave—like paid time off (PTO)—but you may need to adjust these systems to track sick leave accruals based on hours worked.

Your payroll system must deduct the correct amount from each employee’s earnings (0.5%) and remit that amount to fund the paid sick leave program.

Recordkeeping and Notice Requirements

Employers must display paid sick leave notices in both English and Spanish in a visible workplace area. Meanwhile, remote employees must receive notices electronically. This is similar to current labor law posters — you’re simply adding a new one for the paid sick leave expansion.

Employers must include available hours and hours used in the calendar year on employee paystubs. They must also retain relevant records for at least three years, ensuring access upon employee request.

Consult With Legal and HR Experts

Consulting with legal and human resources (HR) experts can confirm that your sick leave policy meets or exceeds Connecticut’s minimum standards. Experts can help you create a policy from the ground up or review your current strategy to determine where modifications are required.

Legal experts can also help you find ways to reduce potential risks related to sick leave claims, especially in cases where sick leave may overlap with FMLA or other state and federal laws.

Review Third-Party Providers

If your business relies on third-party HR or payroll services, make sure these providers are aware of the changes and capable of managing your organization’s paid sick leave requirements. Many providers offer integrated tools for tracking leave accrual and usage, but it’s crucial to confirm that their systems fully comply with the updated law.

Stay Compliant With Mosey

To ensure compliance by the appropriate deadline, employers should start preparing now. That includes updating paid leave policies, implementing payroll tracking systems, budgeting for additional costs, and informing employees about their rights.

By taking proactive steps, businesses can seamlessly adapt to these changes and continue supporting their employees’ well-being while adhering to Connecticut’s paid leave regulations.

Mosey’s compliance automation system helps employers track state and local requirements that impact their business. Our dashboard streamlines every key compliance concern and lets business owners and HR teams quickly and easily check their status. Schedule a demo with Mosey to learn how we can optimize compliance for your organization.

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