The first half of 2025 is off and running with U.S. state and local jurisdiction employment law developments concerning topics such as paid sick leave, family leave, restrictive covenants, anti‑discrimination and AI, pay stub requirements, gender identity protections, and meal and rest breaks, to name a few. As always, minimum wages continue to increase in many jurisdictions and various posters have been updated. See our recent posts on U.S. state employment law developments regarding paid sick leave, family leave, pay transparency, biometric data collection, restrictive covenants, and worker safety acts located here, here, and here.

As always, our team will continue to monitor these and other state employment law developments. If you have questions or need guidance, please reach out to your SPB contact for more information or assistance with compliance.

Arkansas

• Disclosure of sexual harassment allegations – Effective August 4, 2025, H.B. 1643 addresses the circumstances under which current or former employers may disclose substantiated allegations of sexual abuse or harassment by a current or former employee to a prospective employer and limits employers to disclosing such information unless the employer obtains the individual’s written consent. The law also prohibits employers from disclosing that a former employee resigned during an investigation into allegations of sexual abuse or harassment against the former employee, unless that individual provides written consent.

California

• Required notice for crime victim leave updated – The California Civil Rights Department released the mandatory notice for crime victim leave, which employers with 25 or more employees are required to provide to employees upon hire, annually, on request, and whenever an employee discloses victim status. The Department also released guidance on frequently asked questions about the law, which only took effect in January 2025.
• New regulations on use of AI systems – The California Civil Rights Council recently approved new regulations issued under the California Fair Employment and Housing Act, expressly targeting employment discrimination risks arising from AI and other automated decision systems. The regulations add a broad definition of the term “automated-decision system” which covers any tool that makes decisions or assists in human-decision making regarding employment benefits. The regulations apply to the use of such systems in pre-hiring practices and imposes responsibility onto employers for the actions of their agents, including recruiters and staffing firms.

Colorado

• Enforcement framework for wage claims expanded – House Bill 25-1001 amended the state’s Wage Claim Act to increase the minimum wage deduction limit from the federal minimum wage to the state or local minimum wage. The amendments also increase the penalties for willful misclassification of employees and provide for personal liability for individuals who own or control 25% or more of a business. The changes took effect on August 6, 2025.

Florida

• CHOICE Act –The Florida Contracts Honoring Opportunity, Investment, Confidentiality, and Economic Growth (CHOICE) Act was signed by the governor and is effective July 1, 2025. As a very employer-favorable law, this Act provides that certain covered noncompete agreements and covered “garden leave” provisions that extend up to four (4) years are enforceable. The law requires courts to issue an injunction if breach of a covered noncompete or covered leave agreement is alleged. A “covered employee” is defined as any employee or individual contractor who earns or is expected to earn a salary greater than twice the annual mean wage of the Florida county in which the employer has its principal place of business, or the Florida county where the employee resides if the covered employer’s principal place of business is not in Florida. Healthcare practitioners and low wage earners are exempt.

Idaho

• Vaccine mandate ban expanded – Effective July 1, 2025, under S.B. 1210, the Medical Freedom Act (previously known as the Coronavirus Stop Act), expands the definition of a “medical intervention” to include vaccines, medical diagnoses, or treatment, and prohibits employers from using a medical intervention as a term of employment, unless required by federal law or the terms of employment include travel to foreign jurisdictions requiring a medical intervention to enter. Previously, the law only banned COVID vaccination requirements. Employers are prohibited from offering a different salary, hourly wage, or benefits based on whether the employee has or has not received or used a medical intervention.

Illinois

• Retaliation for taking one day off in seven prohibited – As of March 21, 2025, SB3180 prohibits employers from retaliating, taking an adverse action against, or in any manner discriminating against employees for exercising their rights under the state’s One Day Rest in Seven Act, requiring employers to provide employees a minimum of 24 hours of rest within every consecutive 7-day period. Employers in violation of this law may be subject to civil penalties, including fines.
• Chicago, IL updates minimum wage, paid leave, and expands employer coverage under Fair Workweek law – Several changes to the City of Chicago’s employment laws took effect on July 1, 2025. The minimum wage for employees working in the City of Chicago increased to $16.60 for non-tipped workers and to $12.62 for tipped workers. Further, under the Chicago Paid Leave Ordinance, employers with 51-100 covered employees are now required to pay out up to 56 hours of accrued and unused leave upon termination of employment. Finally, on July 1, 2025, the wage threshold for covered employees under the Chicago Fair Workweek Ordinance increased to $32.60 per hour for hourly employees and $62,561.90 annually for salaried employees.
• Artificial Intelligence in the employment process regulated – HB 3773 will amend the Illinois Human Rights Act, effective January 1, 2026, and make it unlawful for employers to use AI that has the effect of discriminating against employees or applicants on the basis of a protected class, including the use of an AI system that relies on zip codes as a proxy for protected classes when making employment decisions. The amendments require the state Department of Human Rights to implement rules and standards prior to the effective date.
• Changes to personnel file access requirements  As of January 1, 2025, under Public Act 103-0727, employees have a right to inspect, copy, and receive copies of additional personnel documents , including documents concerning benefits, employment-related contracts, handbooks and employer policies that employees are subject to and that concern qualifications for employment, promotion, or disciplinary action. The amendments clarify that requests must be made in writing, which includes electronic communications such as test messages or email, to the responsible person or department. The amendments also require employees to identify what personnel records they are requesting or whether they are requesting all records to which they are entitled, to specify who will be performing the inspection or receiving copies of the records, and state whether the employee is requesting to inspect, copy, or receive copies of the records. Further, under the amended law, if requested records include medical information, the employee must include a signed waiver to release medical information or records to an employee’s specific representative along with the employee’s request. The amendments also clarify that employees are not entitled to records that include their employer’s trade secrets, client lists, sales projections and/or financial data.

Indiana

• Leave for school conferences or meetings  – Effective July 1, 2025, employers must allow employees unpaid time off to attend school conferences related to a student’s unexcused absences or a “case conference committee” (related to individualized education programs) at least once per year. Employees must provide at least five days’ notice of the need for leave. Senate Bill 409 expires July 1, 2029.

Iowa

• Gender identity protections removed – Under SF418, “gender identity” was removed from Iowa’s list of protected classes under the Iowa Civil Rights Act. The law further mandates how the “sex” of an individual must be listed on a birth certificate and that the term “gender” shall be considered a synonym for the term “sex” and not considered in relation to gender identity, experienced gender, gender expression, or gender role.
• Iowa drug testing law changes – HF 767 amended Iowa’s private employer drug testing law to provide that an employer has discretion to designate which positions are “safety-sensitive” for purposes of random drug tests. The amendments also allow Iowa employers to provide notice of a positive test result in person or via electronic notification and shift the burden of proof for any lawsuit under the statute to employees or prospective employees.
  Protections for adoptive parents introduced – Under HF 248, Iowa employers are required to treat adoptive parents the same as biological parents for purposes of employment policies, benefits, and protections for the first year of adoption. The law took effect on July 1, 2025.

Kansas

• Noncompetes enforced– Effective July 1, 2025,employer-friendly S.B. 241 provides that noncompetition and nonsolicitation clauses are presumed to be enforceable, as long as they are limited to certain contacts and time periods.

Maine

• Accrual cap for paid time off increased – LD 55 increases the number of legally required paid time off (PTO) employees must be able to accrue each year. Previously, any unused PTO an employee carried over from a previous year would count against their ability to accrue additional hours in the current year. Under LD 55, employees are entitled to accrue additional PTO hours in a new year, even if the employee carried over PTO from the previous year. The amendments did not change the usage cap, however, meaning no employee may use more than 40 hours of leave in a year. The changes take effect on September 24, 2025.

Massachusetts

• Pay Transparency enacted – As we previously covered here, effective October 29, 2025,the Massachusetts Act Relative to Salary Range Transparency will require employers with 25 or more employees to disclose pay ranges.

Michigan

• Child labor law revised – In an effort to provide for better oversight and compliance, H.B. 5594 makes changes to child labor laws. Currently, the director of the state Department of Labor and Economic Opportunity (“DLEO”) may grant certain deviations from established employment standards or hours of employment if determined that is in the best interests of the minor and the community. Effective October 2, 2026, the DLEO must create a registration system that allows minors to register for employment and allows an employer to register to employ minors. Once established, the DLEO will assume responsibility for issuing work permits to minors rather than schools. See the bill for exceptions.

Minnesota

• Earned Sick and Safe Time changes  — Effective July 1, 2025, SF 17 requires Minnesota employees to provide notice of an unforeseeable need to use sick leave “as reasonably required” by their employer, rather than “as soon as practicable.” The amendments also permit employers to require documentation that an employee is using sick leave for a covered reason for absences of more than two consecutive workdays. In addition, the amendments clarify that an employee may voluntarily trade shifts when using sick leave; however, employers are still prohibited from requiring employees to find a replacement worker as a condition of using sick leave.
• Clarifications on employee rest and meal breaks – SF 17 also provides much needed clarity on the required employee breaks under Minnesota law, establishing a mandatory 15-minute rest break within each four consecutive hours of work and a 30-minute unpaid meal period for employees who work six or more consecutive hours. The changes take effect January 1, 2026.
• Minneapolis adds new protected statuses– Effective August 1, 2025, employment discrimination on the basis of height, weight, criminal record or history (referred to as “justice-impacted status”) and housing status are prohibited. “Justice-impacted status” means the ”state of having a criminal record or history, including any arrest, charge, conviction, period of incarceration, or past or current probationary status.” Employers are permitted to consider an applicant’s justice-impacted status if the underlying conduct of the criminal history has a reasonable relationship to the ability to perform the duties of the position. The ordinance applies to all employers regardless of size.

Missouri

• Paid Sick Leave repealed – Effective August 27, 2025, Missouri employers will no longer be required to provide eligible employees with paid sick leave. Last November, Missouri voters approved Proposition A, which took effect on May 1 and required employers to provide eligible employees with one hour of paid sick leave for every 30 hours worked. Because the law does not go into effect until the end of August, employers are required to remain compliant with Proposition A through that date, or until the Missouri Department of Labor publishes guidance for interim compliance with the sick leave law. Last November, Missouri voters approved Proposition A, which took effect on May 1 and required employers to provide eligible employees with one hour of paid sick leave for every 30 hours worked. Because the law does not go into effect until the end of August, employers are required to remain compliant with Proposition A through that date, or until the Missouri Department of Labor publishes guidance for interim compliance with the sick leave law.

Montana

• Volunteer emergency service providers protected – Effective October 1, 2025, employers are prohibited from terminating an employee for being absent or late to work if serving as a volunteer emergency service provider or joining a volunteer emergency unit or organization, as long as the employee has completed their probationary period. Under H.B. 128, an employee must provide written notification of their status as an emergency service provider by November 1, 2025, or within 30 days of hire if hired after October 1, 2025. Time off for these purposes is unpaid.
• Individuals seeking or holding public office protected – Montana law now requires employers of ten or more employees to provide up to 180 days per year of job-protected leave to employees elected or appointed to a public office in the city, county, or state for purposes of performing public service.

Nevada

• Expanded protections for minors– Nevada amended its child labor law to reduce the maximum weekly hours cap for children who are under the age of 16 to 40 hours per week; the cap was previously 48 hours. The amendments also prohibit work between 11:00pm and 6:00am on school nights for any unemancipated child who is enrolled in high school and between the ages of 16 and 19, with certain exceptions. AB 215 is slated to take effect on October 1, 2025.
• Employee protections from wildfire smoke – SB 260 establishes protections for certain employees relating to the exposure to poor air quality from wildfire smoke. Employers with more than 10 employees will be required to monitor air quality, establish protective controls, and provide employees with notice of poor air quality. The regulation will also prohibit employers from allowing an employee to work outdoors under certain air quality conditions and require employers who employ workers that perform work outdoors to provide training to their workforce.
• Civil Air Patrol leave – Under Assembly Bill No. 422, Nevada employees who are volunteer members of the Nevada Wing of the Civil Air Patrol may be entitled to an unpaid leave of absence starting October 1, 2025. Employees are entitled to up to 10 days of leave each year for emergency mission training purposes and up to 30 days per year for purposes of responding to an emergency mission.

New Hampshire

• Lactation accommodation – Effective July 1, 2025, a new law requires employers with six or more employees to provide an employee needing to express breast milk for her infant child unpaid breaks of a reasonable length (e.g., approximately 30 minutes for every three hours of work), for up to one year after the child’s birth, unless providing this break time would impose an undue hardship on the Company’s operations. The break time should, if possible, run concurrently with any break time already provided the employee. The Company must make reasonable efforts to provide a room or other location other than a bathroom, in close proximity to the work area, where the employee can express milk in private.
• Workplace violence – Under a new law, as of January 1, 2025, employees of private employers that receive public funds from the federal or state government in the form of payment for contractual services, grants, or in any other form, and are legally permitted to carry a firearm, must be permitted to store a firearm, not visible and locked in their private motor vehicle in the Company parking lot. Employers may prohibit employees from bringing firearms, explosives, or weapons into the workplace.

New York

• Employer data breach notice required – Since December 21, 2024, employers have been required to notify employees who are New York residents of a security breach involving private personal information within 30 days of discovery. Effective March 17, 2025, A.B. 920 expanded the definition of “private personal information” to include medical and health insurance information, including information regarding an individual’s medical history, medical treatment, and an individual’s health insurance policy number or subscriber identification number. Senate Bill 2659 also requires the employer to notify the state attorney general and the state’s Department of Financial Services of the breach and the approximate number of affected persons, and to provide a copy of the notice sent to the affected employees.
• Increased Jury Duty allowance  — Senate Bill 4998-A amended the amount of allowance that jurors are entitled to under New York law. As of June 8, 2025, employers of 11 or more employees must pay employees who are absent for jury duty $72 per day (or their daily wages, if lower) for the first three days of jury duty.
• Limited damages for late wage payments to manual workers – On May 9, 2025, New York amended Sections 191 and 198 of the New York Labor Law to limit liquidated damages recoverable for late wage payments to manual workers. Liquidated damages are no longer available for frequency-of-pay violations where the employer paid the employee wages on a regular payday that was no less frequent than semi-monthly. Further, although the amendments affirm that employers must continue to pay manual workers on a weekly basis, employers who are paying manual workers at least semi-monthly are not liable until their second offense.
• Increased penalties for child labor law violations – Through Senate Bill S3006C, New York dramatically increased the civil penalties for employers that violate state child labor laws–the penalty for first violations is up to $10,000 from $1,000. The amendments require the state’s Department of Labor to establish a database for the employment of minors. Any employer that employs minors will be required to register on the database and to provide certain information about any minors that it employs. Minors who plan to work for an employer in New York are also required to register on the database. In addition, the amendments will allow minors to electronically register and apply for their mandatory working papers instead of the current in-person filing requirement. 

Ohio

• New pay stub requirements – Effective April 9, 2025, the Pay Stub Protection Act requires Ohio employers to provide employees written or electronic access to their pay stubs, which must include certain specified information. Employees who have not received the required written statement must notify their employer in writing. Employers then have ten days to provide the employee with the statement. Employees who have not received written statements after making such a request and not receiving their statement within ten days, may report violations to Ohio’s director of commerce.
• Space force included in military leave law – As of March 20, 2025, S.B. 154 revised its “armed forces”, and “uniform services” definitions to include space force, ensuring the same protections as in other branches of the military.

Oregon

• Blood donation a qualifying reason to use sick time – On May 20, 2025, the Oregon legislature passed SB 1108, which amends Oregon’s Sick Time Law to include leave for blood donation as a qualifying reason for employees to use paid sick leave hours. The employee must donate blood in connection with a voluntary program approved or accredited by the American Association of Blood Banks or the American Red Cross. The amendment takes effect January 1, 2026.
• Employer’s obligations when faced with allegations of harassment clarified – Amendments to Oregon’s anti-discrimination and anti-harassment laws, which took effect in February 2025, provide much needed clarity on the definitions of “appropriate corrective action” and “promptly correcting harassing behavior” under state law. Oregon’s law provides for employer liability when the employer knew or should have known about harassment unless the employer took immediate and appropriate corrective action to promptly correct the behavior. The amendments provide that an employer takes appropriate corrective action by intervening immediately with actions reasonable designed to halt the harassing behavior, conducting a prompt and adequate investigation to ascertain the extent of the harassing behavior, taking appropriate remedial measures proportionate to the seriousness of the alleged behavior, minimizing or removing the burden on the reporting employee, not retaliating against the reporting employee, and taking reasonably calculated steps to prevent retaliation and future harassment.

Philadelphia, Pennsylvania

• POWER Act amends sick leave, expands domestic worker protections, and increases recordkeeping requirements – On May 27, 2025, the mayor in Philadelphia, Pennsylvania signed the POWER Act into law, taking effect immediately. The POWER Act amended the citywide paid sick leave law to provide that paid sick leave must be paid at the same hourly rate an employee normally earns and increased the threshold for who qualifies as a “tipped employee” under the ordinance. The amendments also provide coverage for non-probationary CBA-covered employees, expand the civil penalties for violations, and increase the retention period for records to two years. Notably, the amendments removed the requirement that employers provide employees with notice of their rights under the ordinance in a handbook, in addition to being provided to the employee or posted in a conspicuous location. The law also requires employers to execute employment contracts with domestic workers no later than the first day of work, provide advance written notice of termination to avoid owing severance, and to provide domestic workers with written notice of their rights. In addition, the new law creates a presumption against employers who fail to produce required records upon request from the city’s Department of Labor. Finally, the POWER Act prohibits employers from taking any adverse action against employees for engaging in protected activity, such as inquiring about their rights or participating in an investigation, and creates a presumption of retaliation when an employer takes an adverse action within 90 days of any protected activity. 

Rhode Island

• Accommodations for menopause-related conditions now required – Effective July 1, 2025, 2025-S 0361 and 2025-H 6161 amend Rhode Island’s fair employment statute to require covered employers to provide reasonable accommodations for menopause-related conditions. The amendments also protect employees from discrimination due to menopause-related conditions in all terms of employment. Employers are covered if they have four or more employees in Rhode Island.
• Mandatory notice requirements for new hires – H 5679, which is slated to take effect January 1, 2026, requires Rhode Island employers to provide all new hires with written notice, in English, containing (a) the rate of pay and basis thereof, (b) allowances, if any, claimed, pursuant to permitted meals and lodging, (c) policies concerning sick, vacation, personal leave, holidays, and hours, (d) employment status, including whether the employee is exempt, (e) the deductions that may be made from the employee’s pay, (f) regularly scheduled paydays, the number of days in the pay period, and the payday on which the employee will receive the first payment of wages, (g) the legal name of the employer and the operating name, if different from its legal name, (h) the physical address for the employer’s main office or principal place of business and, if different, the employer’s mailing address, and (i) the employer’s telephone number. Employers must obtain written acknowledgment of receipt of the notice from all new hires and maintain those records for at least three years after hire.

Vermont

• Pay Transparency law takes effect – As we previously covered here, effective July 1, 2025,Vermont employers are required to include the compensation or range of compensation in each job advertisement, including positions that are open to internal or external candidates and positions into which current employees can transfer or be promoted.

Virginia

• Limits on noncompetition agreements expanded – Effective July 1, 2025, S.B. 1218 prohibits an employer from entering into, or enforcing non-compete agreements with any non-exempt employee, regardless of salary. Previously, the prohibition related to “low wage employees”, or any employee whose average weekly earnings fell below the Viginia average weekly wage. This act does not invalidate, alter, or otherwise affect any contracts, covenants, or agreements entered into or reviewed prior to July 1, 2025.

Washington

• Paid sick leave expanded – H.B. 1875 expands paid sick to permit eligible employees to take paid sick leave to prepare for or participate in judicial or administrative immigration proceedings involving the employee or their family members. Upon request, employees must verify that the leave taken was for immigration proceedings and may submit documentation from various sources. This law takes effect July 27, 2025.
• Coercion based on immigration status prohibited – Effective July 1, 2025, S.B. 5104 prohibits employers from coercing or threatening employees into illegal working conditions or being paid below minimum wage, based on the employee’s or their family’s immigration status. Employers in violation of the law may be subject to civil penalties.
• Enhanced rights to personnel records – Effective July 27, 2025, Washington law defines “personnel file” to mean all job application records, all performance evaluations, all nonactive or close disciplinary records, all leave and reasonable accommodation records, all payroll records, and all employment agreements. HB 1308 also requires employers to respond to a request within 21 days.
• All Washington employers required to provide pregnancy-related accommodations – On May 20, 2025, Governor Ferguson signed SB 5217 into law, extending the requirement to provide pregnancy-related accommodations to all Washington employers with one or more employees, including nonprofit sectarian and religious organizations. The law also requires employers to pay employees their regular rate of pay for lactation breaks and prohibits employers from requiring the use of other paid leave for lactation breaks. These changes take effect on January 1, 2027.
• Mini-WARN Act – Washington recently enacted a mini-WARN act (“WA-WARN Act”), which took effect July 27, 2025. The WA-WARN Act applies to employers with 50 or more full-time employees in the state and requires covered employers to provide 60 days’ advance written notice for mass layoffs or business closures. Unlike the federal WARN Act, a mass layoff under Washington’s new law is not limited to a single site of employment. The law also differs from federal law by imposing broader notice requirements, including mandatory disclosures about whether the closure or layoff is the result of relocation or contracting out the employee’s position. The WA-WARN Act also prohibits employers from including employees on Washington Paid Family and Medical Leave in a mass layoff.
• Employee protections under Paid Family Medical Leave expanded – Effective January 1, 2026, amendments to Washington’s Paid Family and Medical leave program will extend job restoration rights to employees of an employer with 25 or more employees in the state (previously 50 employees). This number will periodically be reduced in 2027 and 2028. The amendments also remove the hours-of-work requirement, meaning job restoration rights apply to any employee who has worked for the employer for at least 180 calendar days before taking leave. The minimum leave duration will also be reduced from eight-hour increments to four-hour increments. Employers may count leave taken under the federal Family and Medical Leave Act against an employee’s job-restoration period only if they provide written notice to the employee within five business days of the employee’s initial request for or use of FMLA leave and then monthly thereafter during the leave year. 

West Virginia

• Expanded definition of “harassment” – West Virginia’s legislature amended the definition of “harassment” to include intimidation, meaning an act or course of conduct directed at a specific person and intended to cause fear or apprehend fear. HB 2391 took effect on February 14, 2025.
• Pregnant workers’ fairness act (“PWFA”) – In keeping with the legislature’s timeline, the W. Va. Office of the Inspector General adopted rules regarding the PWFA and identified reasonable accommodations related to pregnancy and factors to consider in determining whether the accommodations impose an undue hardship on employers. In determining whether a reasonable accommodation creates an undue hardship on the employer, factors such as the nature and cost of the accommodation, and financial resources of the employer may be considered. “Reasonable accommodation” may include making existing facilities readily accessible, and job restructuring.