Connecticut’s paid sick leave law is about to reach its final, and broadest, phase of expansion. Beginning January 1, 2027, Connecticut employers with just one employee will be required to provide paid sick leave. This means that many small businesses and nonprofit organizations not previously covered by the law will soon have new obligations.
For many nonprofits and small employers, now is the time to review existing leave policies, payroll practices, and employee handbooks to ensure they are ready for the change.
Who Will Be Covered?
Connecticut has been expanding its paid sick leave law in stages. The law previously applied to certain larger employers and certain types of employees (“service workers”). In 2025, the law was expanded to all employers with 25 or more employees. On January 1, 2026, the threshold dropped to 11 or more employees. Beginning January 1, 2027, the law will apply to employers with one or more employees.
The employee-count determination is based on the employer’s payroll for the week containing January 1 each year. As a result, even a very small nonprofit or employer that has only one employee on its payroll may fall within the law beginning in 2027.
There are limited exceptions, including certain construction-related employees covered by qualifying multiemployer health plans and self-employed individuals. Seasonal employees also generally are not covered.
How Much Paid Sick Leave Must Be Provided and When Can It Be Used?
Covered employees accrue paid sick leave at a rate of one hour for every 30 hours worked, up to a maximum of 40 hours per year. This is a very common standard across the United States. Employers may provide more leave or allow employees to accrue leave at a faster rate.
Employees may carry into the following year up to 40 hours of unused accrued sick leave. However, employees are not entitled to use more than 40 hours of paid sick leave in a year regardless of the total amount they have earned. Alternatively, an employer may choose to provide 40 hours of leave at the beginning of the year instead of allowing carry over of unused hours.
For employees who are already employed when the law takes effect, accrual begins January 1, 2027. For employees hired after that date, accrual begins on the employee’s first day of employment. Employees may begin using accrued leave after 120 calendar days of employment.
For What Purposes Can Employees Use Paid Sick Leave?
The law provides paid sick leave for much more than an employee simply being sick.
Employees may use leave for their own illness, injury, medical care, preventive care, or mental health wellness day. They may also use leave to care for a family member’s illness, injury, medical care, or preventive care.
Beyond traditional illness issues, the law also covers circumstances involving:
- A workplace or a family member’s school or place of care being closed because of a public health emergency;
- An employee or family member being determined to pose a health risk because of exposure to a communicable disease; and
- Certain medical, counseling, relocation, and other needs arising from family violence or sexual assault.
The definition of “family member” is also broad. It includes a spouse, sibling, child, grandparent, grandchild, parent, and certain individuals whose close association with the employee is equivalent to one of those family relationships.
Employers Generally Cannot Require a Doctor’s Note
One important change for newly covered employers is the law does not permit an employer to require an employee to provide documentation showing the reason for the leave (e.g., a doctor’s note).
Employers also cannot retaliate against or discriminate against an employee for requesting or using paid sick leave or for filing a related complaint with the Connecticut Department of Labor.
What About an Existing PTO Policy? Employers should not assume they need to create a separate “paid sick leave” bank. An employer may comply with Connecticut’s law by providing another form of paid leave (such as paid time off, vacation, or personal leave) if the leave can be used for the purposes covered by the paid sick leave law and is accrued at least as quickly as required under the statute. The law expressly permits employers to use an existing paid leave policy to satisfy the requirement. This can be particularly helpful for small employers and nonprofits that already provide PTO to their employees.
However, employers should carefully review their existing policies. A PTO policy that does not provide employees with the same rights and protections required by the paid sick leave law will not be sufficient.
Don’t Forget Recordkeeping and Notice Requirements
Employers covered by the law must track and maintain records of hours worked, and paid sick leave accrued and used. Connecticut Department of Labor requires these records be maintained for at least three years.
Employers also have obligations to notify employees of their paid sick leave rights. The Connecticut Department of Labor provides a paid sick leave poster employers can use to satisfy the notice requirement. The Department of Labor provide the notice in both English and Spanish.
Employers should also make sure their employee handbooks and written leave policies accurately describe how employees accrue and use paid leave.
What Should Small Employers and Nonprofits Do Now?
January 1, 2027, may seem far away, but employers that have never been subject to Connecticut’s paid sick leave law should start preparing now.
We recommend the following:
- Determine whether the organization will be covered. For 2027, the threshold is generally just one employee.
- Review existing PTO and leave policies. An existing policy may satisfy the law, but it must provide leave that meets the statutory requirements.
- Review payroll and timekeeping systems. Make sure the organization accurately tracks hours worked as well as paid sick leave accrued and used.
- Review employee handbooks. Update leave policies if necessary.
- Prepare required employee notices.
- Train managers and supervisors. Supervisors must understand employees cannot be required to find a replacement or provide prohibited documentation when using protected paid sick leave.
- Coordinate with payroll or outside HR providers. Small organizations that outsource payroll or HR functions should confirm their systems will be ready for the January 1, 2027, expansion.
The Bottom Line
Connecticut’s paid sick leave law will soon apply to employers that have never had to comply with it before. For small employers and nonprofits, the most important date is January 1, 2027.
Organizations with only one or a handful of employees should not wait until the end of the year to address the new requirements. Review leave policies, payroll systems, recordkeeping practices, and employee notices now to help avoid compliance problems later.
If your Connecticut business has fewer than 11 employees, now is a good time to determine whether your current policies will satisfy the law when the final phase of Connecticut’s paid sick leave expansion takes effect on January 1, 2027. Our Firm regularly assists employers with reviewing and updating their paid leave policies, employee handbooks, and compliance practices
Brody and Associates regularly advises management on compliance with the latest local, state and federal employment laws. If we can be of assistance in this area, please contact us at info@brodyandassociates.com or 203.454.0560.
