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India: Amendments to Labour Law Framework 

On 21 November 2025, the Government of India implemented four consolidated Labour Codes: the Code on Wages (2019), the Industrial Relations Code (2020), the Code on Social Security (2020), and the Occupational Safety, Health and Working Conditions (OSHWC) Code (2020). These Codes replace 29 existing Central labour laws with a unified statutory framework governing wage, social security, working conditions, and industrial relations. These Labour Codes aim to modernise India’s labour framework, reduce statutory fragmentation, and align legal definitions and obligations with contemporary workforce structures. 

The full operational rollout of the Labour Codes will proceed in a phased manner due to labour being a subject under the Concurrent List of the Indian Constitution. Hence each State Government will independently develop and issue its own rules and procedural frameworks in alignment with the central legislation. 

Until individual state-level rules are formally notified, the existing provisions under prior state labour laws and regulations will remain in effect. As a result, there is a transitional period where older state rules coexist alongside the newly introduced central Codes, creating a temporary dual-compliance environment for employers operating across multiple jurisdictions. 

Key Substantive Changes: 

This section focuses on the major legal changes compared to the previous framework, particularly those affecting time tracking, payroll accuracy, and workforce classification. 

Working Hours & Overtime 

Previously, multiple acts applied simultaneously to various employers (Factories Act, Shops & Establishments Acts) with varying daily limits of working time (often 9 hours/day). 

Effective 21 November 2025, the OSHWC Code standardises working hours across establishments. The new framework permits 8 to 12 working hours per day, subject to an overall cap of 48 hours per week. 

Overtime: Any work beyond the prescribed working hours is considered as overtime work. Overtime must be compensated at not less than double the employee’s regular rate of pay and may only be assigned with the explicit consent of the employee. 

What remains unchanged is the 48-hour weekly limit and the continued requirement to provide employees with statutory weekly rest, which are consistent with the earlier regime. 

Karnataka  

Current Law : Karnataka Shops and Commercial Establishments Act, 1961 and Karnataka Shops and Commercial Establishments Rules, 1963 

Working Hours: An employee’s daily working hours shall not exceed more than 9 hours per day and 48 hours per week. 

Overtime: Any work performed beyond 9 hours per day and 48 hours a week is considered as overtime. An employee working hour including overtime shall not exceed 10 hours per day. Hence, a maximum of 1 hours of overtime can be performed in a day. 

Total number of overtime hours shall not exceed 50 hours in a period of 3 consecutive months. 

Pay : Employee is entitled to receive at least double their regular rate of pay for overtime work. 

Breaks and spread over: Employees shall not be allowed to work for more than 5 hours without an unpaid break period of at least 1 hour. 

The spread-over of working hours in a day, inclusive of breaks, must not exceed 12 hours, as mandated under the Karnataka Shops and Commercial Establishments Act, 1961. 

Proposed Amendments  

The Karnataka Labour Department has issued draft amendments to the Karnataka Shops and Commercial Establishments Act, 1961, proposing revisions to working hours and overtime regulations. These amendments are only at the draft stage and have not yet been enacted or officially notified. 

Reference: Proposed alignment with the Occupational Safety, Health and Working Conditions Code, 2020 and forthcoming state rules. 

Working Hours (Proposed):  Employees daily working-hour limit would be increased to 10 hours a day, while the weekly limit would remain fixed at 48 hours a week. 

Overtime (Proposed): The daily working time including overtime work would increase from 10 hours to 12 hours a day.

The quarterly overtime ceiling is proposed to increase to approximately 144 hours, while the overtime pay rate would continue to be payable at twice the employee’s regular rate of pay for overtime work. 

Breaks / Spread over (Proposed): Employees would be entitled to a rest break after 6 continuous hours of work.

Haryana 

Current Law : The Haryana Shops and Commercial Establishments (Amendment) Ordinance, 2025 

Effective Date: November 12, 2025 (promulgated under Article 213 of the Constitution of India) 

Legal Status: This is an Ordinance that has been promulgated and is currently in force. It will be tabled in the upcoming winter session of the Haryana Legislative Assembly for conversion into an Act. 

Working Hours: The daily working hour limit is increased to 10 hours/day, while retaining the weekly cap of approximately 48 hours/week. 

Overtime: Any work beyond 10 hours a day and 48 hours a week is overtime. The quarterly overtime limits are expanded up to 156 hours per quarter. Overtime must be paid at double the employee’s regular rate of pay for overtime work, and: 

• Employee consent is mandatory 
• Detailed OT registers must be maintained 
• Employers must avoid coercion and ensure voluntary overtime 

Breaks: The maximum period of continuous work before a mandatory rest interval has been extended from 5 hours to 6 hours. 

Previously: Governing Act: The Punjab Shops and Commercial Establishments Act, 1958 (as applicable to Haryana) 

Working Hours: An employee’s daily working hours shall not exceed more than 9 hours per day and 48 hours per week. 

Overtime: Any work performed beyond 9 hours per day and 48 hours a week is considered as overtime. An employee working hour including overtime shall not exceed 10 hours per day. Hence, a maximum of 1 hours of overtime can be performed in a day. 

Total number of overtime hours shall not exceed 50 hours in a period of 3 consecutive months. 

Pay: Employee is entitled to receive at least double their regular rate of pay for overtime work. 

Breaks and spread over: Employees shall not be allowed to work for more than 5 hours without an unpaid break period of at least 30 minutes. 

The spread-over of working hours in a day, inclusive of breaks, must not exceed 12 hours per day. 

Maharashtra 

Current Law : Maharashtra Shops and Establishments (Amendment) Ordinance, 2025 

The Maharashtra Shops and Establishments (Amendment) Ordinance, 2025, effective 1 October 2025, is currently in force as an Ordinance. It will remain valid for six weeks from the reassembly of the State Legislature and must be converted into an Act by the Maharashtra Legislative Assembly to become permanent law. 

Working Hours: An employee daily working hours is increase up to 10 hours/day and 48 hours per week.

Some categories/establishments (especially continuous-process or special zones) granted expanded flexibility 

Overtime: Any work beyond 10 hours a day and 48 hours a week is Overtime. The quarterly overtime ceiling increased from 125 hours to 144 hours/quarter. The employer and employee must follow the key obligations: 

• Overtime must be voluntary 
• Paid at double the employee’s regular rate of pay for overtime work
• Employer must maintain digital/physical overtime registers.

Night Work / Women: Women can work night shifts with written consent, provided the employer ensures: 

• Safe & GPS-enabled transport 
• CCTV coverage 
• Female supervisors 
• Well-lit workplace & restrooms 
• No back-to-back day/night shifts This is now formally allowed without needing special case-by-case permissions. 

Breaks / Spread-over: Employees shall not be allowed to work for more than 6 hours without an unpaid break period of at least 30 minutes. 

The spread-over of working hours in a day, inclusive of breaks, must not exceed 12 hours per day. 

Previously: Governing Act: The Maharashtra Shops and Establishments (Regulation of Employment and Conditions of Service) Act, 2017 

Working Hours: An employee’s daily working hours shall not exceed more than 9 hours per day and 48 hours per week. 

Overtime: Any work performed beyond 9 hours per day and 48 hours a week is considered as overtime.

Total number of overtime hours shall not exceed 125 hours in a period of 3 consecutive months. 

Pay : Employee is entitled to receive at least double their regular rate of pay for overtime work. 

Breaks and spread over: Employees shall not be allowed to work for more than 5 hours without an unpaid break period of at least 30 minutes. 

The spread-over of working hours in a day, inclusive of breaks, must not exceed 10.5 hours per day. 

Night Work / Women: Earlier, women’s night work (between 7 PM – 6 AM) was restricted unless employers obtained permission and ensured safety conditions, including transport and security. Permissions were generally granted but not automatically allowed. 

Andhra Pradesh 

Current Law : The Andhra Pradesh Shops and Establishments (Amendment) Act, 2025 

Working Hours: An employee daily working hours is increase up to 10 hours/day and 48 hours per week. 

Overtime: Any work beyond 10 hours a day and 48 hours a week is overtime. . The quarterly overtime limits is expanded up to 144 hours per quarter. Overtime must be paid at double the employee’s regular rate of pay for overtime work. The employer and employee must follow the key obligations: 

• Overtime must be voluntary 
• Paid at double the employee’s regular rate of pay for overtime work. 
• Employer must maintain digital/physical overtime registers 

Breaks and spread over: Employees shall not be allowed to work for more than 6 hours without an unpaid break period of at least 30 minutes. 

Previously: Governing Act: The Andhra Pradesh Shops and Establishments Act, 1988 (Act No. 20 of 1988) 

Working Hours: An employee’s daily working hours shall not exceed more than 8 hours per day and 48 hours per week. 

Overtime: Any work performed beyond 8 hours per day and 48 hours a week is considered as overtime. No employee shall be allowed to work overtime, for more than 7 days at a stretch. 

Total number of overtime hours shall not exceed 50 hours in a period of 3 consecutive months. 

Pay: Employee is entitled to receive at least double their regular rate of pay for overtime work. 

Breaks and spread over: Employees shall not be allowed to work for more than 5 hours without an unpaid break period of at least 1 hour. 

The period of work of an employee inclusive of interval for rest shall not spread over for more than 12 hours (inclusive of overtime) in any day. 

Several Indian States such as Uttar Pradesh, Delhi, Gujarat, Odisha, and West Bengal etc have either enacted or released similar draft amendments to their respective Shops and Establishments Acts with the objective of aligning their regulatory frameworks with the anticipated implementation of the Central Labour Codes and responding to evolving economic and operational requirements. 

These state-level reforms broadly reflect a move toward harmonised standards, including longer permissible daily working hours, expanded quarterly overtime ceilings, more liberal night-shift permissions for women subject to safety conditions, and reduced compliance obligations for smaller establishments. 

Leave & Gratuity Reforms 

Previously, employees became eligible for annual leave only upon completing 240 days of work in a calendar year.  

Under the new regime, this eligibility threshold for availing annual leave is reduced to 180 days, thereby enabling earlier access to earned leave. The entitlement structure remains unchanged, with employees continuing to accrue one day of leave for every twenty days of actual work performed. 

The new framework also clarifies that periods of lay-off, maternity leave, and approved leave count toward the 180-day eligibility calculation, strengthening employee protections. Accrued annual leave continues to be carried forward and encashed in accordance with statutory limits, though state rules may prescribe specific caps. 

Women Working at Night 

Previously, many state laws restricted women from working at night unless employers obtained specific exemptions, resulting in inconsistent and limited permissions across jurisdictions. 

Under the new regime, women may be employed during night shifts, provided employers implement mandatory safeguards such as secure transportation, workplace safety measures, and written consent creating a uniform and regulated framework for night work. 

Key Employer Obligations and Compliance Considerations  

As the Codes move toward full implementation, employers should prioritise compliance areas that directly affect workforce structuring, payroll accuracy, time management, and regulatory exposure.

Workforce Classification

• Reassess all categories of workers permanent, fixed-term, gig, and platform to ensure alignment with statutory definitions. 
• Identify and mitigate misclassification risks that may trigger retrospective social-security liabilities.

Employment Documentation and Policies

• Update appointment letters, HR policies, shift regulations, and standing orders to reflect new requirements. 
• Incorporate provisions on overtime consent, night-work conditions, leave eligibility, and fixed-term employment. 
• Review vendor and contractor agreements in light of restrictions on engagement of contract labour in core activities. 

Wage Structure and Payroll Compliance

• Conduct a wage-structure review to confirm allowances do not exceed the 50% statutory cap. 
• Recalibrate PF, ESI, gratuity, overtime, and leave encashment calculations. 
• Ensure payroll systems track statutory payment deadlines across all categories of workers. 

Time and Attendance Governance

• Strengthen mechanisms for recording working hours, breaks, and shift patterns. 
• Ensure written employee consent is captured for overtime, which is now uniformly payable at twice the ordinary rate. 
• Maintain digital attendance and wage registers to support audits under the inspector-cum-facilitator model, which relies on online and risk-based inspections.

Multi-State Compliance Management

• Monitor state-specific rules as they are notified, recognising that implementation timelines and thresholds may vary. 
• Prepare for parallel applicability of legacy state laws and the Codes during the transition period. 
• Develop jurisdiction-wise compliance matrices until uniform nationwide enforcement is achieved. 

Take away: India’s Labour Codes signal a major move toward a unified and modern regulatory framework. While legally in force, full implementation depends on state-level rulemaking. Employers should use this transition period to enhance time-tracking, statutory wage calculations, and multi-state compliance systems to ensure readiness for complete enforcement. 

 

Thailand: Upcoming Amendments to the Labour Law Provisions

Thailand has recently amended the Labour Protection Act, B.E. 2568 (“the Act”), expanding employee leave protections and strengthening employer obligations. Effective 7 December 2025, the amendments increase maternity leave, introduce supplemental leave for mothers caring for newborns with health conditions, provide paid spousal leave for childbirth, and mandate annual reporting by employers with a workforce of ten or more. 

Key changes to the amendments are as follows:  

Maternity Leave 

Currently, female employees are entitled to 98 days of maternity leave each pregnancy. The employer must pay the employee their regular rate of pay for the initial 45 days, and eligible employees shall receive benefits from the Social Security Fund at 50% of their average salary for the remaining days. 

Effective December 7, 2025, employees will be entitled to receive 120 days of maternity leave each pregnancy.  

Pay: The employee will be entitled to receive full pay at their regular rate of wages from the employer for the initial 60 days. The remaining days of the maternity leave will be compensated by the Social Security Fund for employees who meet the eligibility criteria. 

Additional Maternity Leave for Newborn’s Illness 

Currently, there is no additional maternity leave entitlement for mothers whose newborns have illnesses, developmental disorders, or disabilities. 

Effective December 7, 2025, female employee will be entitled to receive additional 15 days of consecutive maternity leave in case their newborns have illnesses, developmental disorders, or disabilities. 

Pay– An employee will be entitled to receive 15 days of paid leave from their employer at 50% of their regular rate of pay for this period. 

Notice Requirement– An employee must submit medical certification to their employer confirming the condition of their newborns from a licensed medical practitioner.  

Spousal Leave for Childbirth (Paternity Leave) 

Currently, there is no spousal leave for employees whose spouses give birth. 

Effective December 7, 2025, employees whose spouse gives birth will be entitled to receive 15 days of paid leave from their employer. This leave shall be taken before or within 90 days of childbirth. 

Employer Reporting Obligations  

Currently, employers are required to submit employment and working conditions reports only upon written request from a labour inspector. 

Effective December 7, 2025, all employers with 10 or more employees must submit an annual report on employment and working conditions to the Director General by January of each year. 

Take Away– Employers should review and update their internal policies to align with these upcoming requirements.   

Canada: Proposed Amendments to Labour Law Provisions 

Canada will implement substantial amendments to labour law provisions, effective 12 December 2025 at the federal level and 1 January 2026 in Saskatchewan. 

Canada Federal- Effective December 12, 2025 (Bill C-59) 

Pregnancy Loss Leave  

Currently, there is no specific federal leave for pregnancy loss under the Canada Labour Code. 

Effective December 12, 2025, a new time off – Pregnancy Loss Leave will be introduced under the Canada Labour Code, outlining the following leave provisions for eligible employees:  

Duration of the Leave:  Eligible employees are entitled to receive: 

• up to 8 weeks of leave if the pregnancy results in a stillbirth (a pregnancy loss at or after 20 weeks of gestation or where the foetus is of at least 500 grams, with no signs of life after delivery). 
• up to 3 working days of leave for any other type of pregnancy loss. 

Entitlement of the Leave:  This leave applies to employees in any of the following situations: 

• the employee’s own pregnancy does not result in a live birth. 
• the pregnancy of the employee’s spouse or common-law partner does not result in a live birth. 
• the employee intended to be a legal parent of a child that would have been born had another person’s pregnancy (such as a surrogate’s) resulted in a live birth. 

Multiple Pregnancy: In the case of a multiple pregnancy, the employee shall be entitled to a single period of leave entitlement, irrespective of the number of childbirths, where at least one does not result in a live birth. 

Pay: Employees who have completed at least 3 consecutive months of continuous employment are entitled to receive their regular rate of pay for their normal hours of work for the first 3 days of this leave, paid by the employer. Any additional days taken beyond the first 3 will be unpaid leave. 

Timing of the leave: The leave period begins on the day the pregnancy does not result in a live birth and may be taken at any time up to 26 weeks after that date. Employees have the flexibility to take this leave in 1 or 2 separate periods, provided that each period is at least 1 day in length. 

Bereavement Leave  

Currently, employees are entitled to receive up to 10 working days of bereavement leave following the death of an immediate family member. Employees who have completed at least 3 consecutive months of continuous employment with the same employer are entitled to have the first 3 days of bereavement leave paid at their regular rate of pay for their normal hours of work. The remaining days, if taken, are unpaid. 

Effective December 12, 2025, the existing bereavement leave entitlements will remain unchanged, and a new, separate provision will be introduced to provide up to 8 weeks of unpaid leave in the event of the death or stillbirth of an employee’s child or the child of their spouse or common-law partner. 

Saskatchewan- Effective January 1, 2026  (Bill 5) 

Sick Leave 

Currently, employees are entitled to up to 12 weeks of unpaid sick leave with serious illness. 

Effective January 1, 2026, the duration of unpaid sick leave with serious illness will increase from 12 weeks to 27 weeks. 

Medical Certificate Requirement for Sick Leave 

Currently, employers can request a medical certificate for any absence due to sickness or injury. 

Effective January 1, 2026, employers cannot request a medical certificate unless an absence exceeds 5 consecutive working days, or the employee has been absent twice for 2 or more days in the preceding 12 months. 

Pregnancy Loss Leave 

Currently, employees are entitled to pregnancy leave following a pregnancy loss that occurs up to 13 weeks before the expected date of birth due to a miscarriage or stillbirth. 

Effective January 1, 2026, the qualifying period has been expanded, and employees will be entitled to pregnancy leave following a pregnancy loss that occurs up to 20 weeks before the expected date of birth due to a miscarriage or stillbirth. 

Bereavement Leave 

Currently, employees are entitled to 5 working days of unpaid bereavement leave in the case of the death of a member of the employee’s immediate family, which must be taken within the period beginning one week before and ending one week after the funeral. 

Effective January 1, 2026, bereavement leave will become more flexible. Employees will continue to be entitled to 5 working days of leave; however, they may now take this leave at any time within six months of the death, rather than being restricted to the days immediately surrounding the funeral. 

The eligibility for bereavement leave has also been expanded to include leave for the death of a person the employee considers to be “like” family, as well as for the loss of a pregnancy of an employee or an employee’s immediate family. 

Interpersonal Violence Leave 

Currently, employees are entitled to 10 working days (5 days are paid leave) of leave each year in case of interpersonal violence leave. 

Effective January 1, 2026, employees are also entitled to an additional 16 weeks of unpaid interpersonal violence leave, which is added in addition to the existing 10 day leave period.  

Expansion of Definition of a “Day” 

Currently, the law defines a “day” as any period of 24 consecutive hours for the purposes of overtime and hours of work. 

Effective January 1, 2026, employers may now define a “day” for the purposes of overtime and hours of work as either: 

• a calendar day, or 
• any other period of 24 consecutive hours commencing at the time the employee is scheduled to begin work. 

Modified Work Arrangements 

Currently, part-time employees are not eligible to participate in modified work arrangements, and any overtime must be calculated once the employee exceeds 8 hours of work a day.  

Example: If a part-time employee is scheduled to work 5 hours per day, overtime would only begin after the employee works more than 8 hours in that day, even though their regular schedule is shorter. 

(A Modified Work Arrangement is an agreement between an employer and employee that averages hours of work over 1 to 4 weeks, allowing employees to work longer days in exchange for more days off.) 

Effective January 1, 2026, part-time employees may be covered by modified work arrangements under which overtime will only be payable once the employee exceeds the number of hours set out in their agreed part-time schedule, instead of the standard eight-hour daily threshold. 

Example: If a part-time employee is scheduled to work 6 hours per day, overtime will only apply after the employee works more than 6 hours on that day—not after 8 hours. 

Weekly days off for Retal Business 

Currently, employees working in retail businesses with more than 10 employees are entitled to 2 consecutive days off per week. 

Effective January 1, 2026, this requirement will be removed. Retail businesses will now be aligned with other sectors, which are required to provide 1 day off per week. 

Take Away- Employers should begin preparing now by reviewing and updating internal policies to align with the upcoming requirements.  

 

 

Spain: Proposed Royal Decree on Digital Working Hours Registration 

Spain has proposed a significant reform to its working-time recording rules. The forthcoming Royal Decree on the Recording of Working Hours aims to modernise the system of recording working time by introducing a mandatory digital recording framework to ensure consistency, transparency, and stronger compliance with labour law. 

The Royal Decree is expected to be issued in late 2025 or early 2026 and will take effect 20 days after its publication in the Boletín Oficial del Estado. 

Currently, employers must ensure a daily record of each employee’s working hours, showing the exact start and end times of the workday. The recording method may be agreed through a collective bargaining agreement, a company policy, or decided by the employer after consulting employee representatives. These records must be kept for 4 years and be accessible to employees, their representatives, and the Labour and Social Security Inspectorate upon request. 

The proposed regulation will bring several important changes for employers in Spain: 

Digital obligation: All companies shall use a digital time-tracking system. The system must be objective, reliable, and tamper-proof, ensuring no data can be changed without proper authorisation. 

Scope of application: The obligation applies to all employees, including senior executives, part-time, temporary, remote, and hybrid workers. 

Recording information in digital records: 

• employee identification 
• work schedule (full-time or part-time, and applicable percentage) 
• exact start and end times and breaks 
• work location (on-site or remote) 
• type of hours (ordinary, overtime, supplementary), with details of compensation (paid or time off) 
• start and end times of waiting or on-call periods not counted as active work 
• hours worked under flexible or irregular schedules 
• daily and monthly summaries of total hours worked 
• identification and authorisation for any modifications 
• recorded interruptions or disconnection periods in line with legal or contractual rights 

Protocol and training: Employers must prepare a written protocol on how the system will operate, after consultation with employee representatives. 

Employees must be trained in how to use the system. Training time counts as working time and cannot be at the employee’s expense. 

System compliance: Employers are required to use a certified or compliant digital time tracking system that meets the legal standards of objectivity, reliability, and accessibility. If an alternative tool is used that is not officially certified, employers must prepare a technical report from a qualified expert to justify its suitability. 

Access rights: Employees must be able to view and obtain copies of their working time records at any time. A summary of hours worked must accompany each payslip. Employee representatives may access the records, but data must be anonymised for privacy protection. 

Labour authority access: The Labour and Social Security Inspectorate must have immediate on-site and remote access to all digital records. 

Record retention: All records must be securely stored for 4 years, in line with Spanish and EU data protection laws. 

Take Away- Employers should begin preparing now by reviewing and updating internal policies, evaluating digital time-tracking solutions, to ensure that systems align with the upcoming recording requirements.  

United States: Upcoming Amendments to Labour Law Provisions  

Effective January 2026, several states across the United States are bringing about significant changes in their respective labour law provisions.   

Read on as we cover these changes in detail – 

Minnesota: New Paid Family and Medical Leave Program  

Currently, Minnesota has no state-mandated paid family and medical leave program. Employers may provide such benefits voluntarily, but there is no legal requirement for wage replacement during qualifying leave events. 

Effective January 1, 2026, the eligible employees will be entitled to receive Paid Family and Medical Leave. 

Duration of the leave: Eligible employees will be entitled to receive: 

• up to 12 weeks of paid medical leave for an employee’s serious health condition 
• up to 12 weeks of paid family leave for caregiving, bonding, military events, or safe leave 
• a combined maximum of 20 weeks in a benefit year if both medical and family leave is used.  

Leaves may be taken continuously, intermittently, or on a reduced schedule, subject to certification and notice requirements. 

The benefit year commences on the first day the employee begins the leave under the PFML program. 

Eligibility Criteria: An individual is eligible for benefits if they: 

• have earned wages in Minnesota during the base period (approximately 5.3% of the state average annual wage threshold), 
• have worked at least 50% of their time in Minnesota, and
• the Act also allows self-employed individuals and independent contractors to opt in coverage through voluntary participation. 

Usage of the leave: Employees are entitled to use leave under following circumstances: 

• Medical Leave: The employee’s own serious health condition, including incapacity due to pregnancy, childbirth, or recovery therefrom.
• Family Leave  
  • bonding with a child following birth, adoption, or foster care placement; 
  • caring for a family member with a serious health condition; 
  • a qualifying exigency arising from a family member’s military service; 
  • safety leave for matters relating to domestic abuse, sexual assault, or stalking. 

The term “family member” is broadly defined to include spouses, partners, children, parents, grandparents, grandchildren, siblings, and certain individuals with equivalent caregiving relationships. 

Pay: An employee will be entitled to receive pay benefits from Social Security unless the employer has opted for a private plan. 

Notice Requirement: An employee must provide the employer with at least 30 days’ written notice of the anticipated start date of the leave whenever the need for leave is foreseeable. If the need for leave is not foreseeable, the employee must give notice as soon as practicable to their employer. 

Minnesota:  New Meal and Rest Break  

Currently, Minnesota employers must allow employees “adequate time from work” within each 4 consecutive hours of work to use the nearest convenient restroom. For meal breaks, if an employee works 8 or more consecutive hours, the employer must permit the employee “sufficient time to eat a meal.”  

Effective January 1, 2026, eligible employees will be entitled to receive a paid rest break of at least 15 minutes or enough time to use the nearest convenient restroom, whichever is longer within every 4 consecutive hours of work. For meal breaks, employers must provide each employee working 6 or more consecutive hours with a meal break of at least 30 minutes. 

Colorado: FAMLI NICU Care Expansion 

Currently, Colorado’s Paid Family & Medical Leave Insurance program (FAMLI) currently allows eligible employees to take up to 12 weeks of leave for qualifying reasons (serious health condition, bonding, etc. 

Before this amendment, parents whose newborns required care in a Neonatal Intensive Care Unit (NICU) could only use their standard 12 weeks of paid leave under FAMLI, typically categorized as “bonding” or “family care” leave. Once those 12 weeks were exhausted, no additional entitlement existed under state law for NICU-related care. 

Effective January 1, 2026, The FAMLI NICU Care Amendment expands FAMLI benefits to include a separate, additional 12 weeks of paid leave specifically for parents whose newborns require care in a neonatal intensive care unit (NICU) or other specialized infant care unit. 

Key Provisions: 

Additional 12 weeks: Parents of newborns in NICU care will be entitled to an extra 12 weeks of paid FAMLI leave, in addition to the standard 12 weeks of bonding leave.

This means eligible parents may now receive up to 24 weeks total of paid FAMLI leave for that benefit year (12 bonding + 12 NICU). 

Eligibility Criteria: The leave shall apply to both parents, regardless of gender or marital status, provided they meet standard FAMLI eligibility criteria (i.e., have earned at least $2,500 in wages subject to FAMLI premiums in the previous year). 

Notice Requirement: The employee shall give notice as soon as possible. 

In case of a foreseeable situation, if parents know in advance that their newborn will require specialized post-delivery care (e.g., anticipated premature birth or medical condition), they shall give up to 30 days of advance notice to their employer.  

Maine: Paid Family & Medical Leave 

Currently, Maine has unpaid job-protected leave (the Maine Family & Medical Leave Requirements Act) for certain employers and employees. 

Effective January 1, 2026, an eligible employee in Maine will be entitled to receive Paid Family and Medical Leave. 

Duration of Leave: Employees will be entitled to take up to 12 weeks of paid family leave and 12 weeks of paid medical leave in a benefit year. 

However, total combined leave (family + medical) cannot exceed 12 weeks per year. 

The law allows an employee to take medical leave immediately followed by family leave (for example, pregnancy recovery followed by parental bonding) when certified by a healthcare provider. 

Leaves can be taken intermittently in at least one-day increments, unless the employer agrees to smaller periods (but not less than one hour). 

Eligibility Criteria: To qualify for Maine Paid Family and Medical Leave (PFML) benefits, an individual must: 

• be employed by a covered employer in Maine, or be a self-employed person who has voluntarily opted into the program. 
• during the base period (the first four of the last five completed calendar quarters immediately preceding the benefit year), have earned wages paid in Maine equal to at least six times the State Average Weekly Wage (SAWW). 

Usage of Leave: An employee shall be entitled to receive leave under following conditions: 

• bonding with a newborn, adopted, or foster child within 12 months of placement or birth. 
• caring for a family member with a serious health condition. 
• attending a qualifying exigency related to a family member’s military service. 
• caring for a covered service member who is a family member. 
• safe leave, such as for reasons related to domestic violence, sexual assault, or stalking. 
• any other reason recognized under Maine’s labour statute. 

Pay: Employees will be entitled to receive a weekly payment based on a percentage of their average weekly wage, up to a maximum limit set by the state. 

Notice Requirements: Employees are required to give reasonable advance notice before taking leave, except in emergencies or sudden illness. 

Employment Protection and Benefits– Employees on PFML continue to accrue employment benefits such as vacation, sick leave, bonuses, seniority, and advancement opportunities as if they were still working.

Note: PFML leave runs concurrently with federal FMLA and Maine’s state family leave laws, where applicable. Employees who do not qualify under FMLA may still use PFML benefits. Employers cannot require employees to use their accrued vacation, sick, or personal time before or during PFML leave. 

Delaware: Paid Family and Medical Leave Insurance Program 

Currently, Delaware has no Paid Family & Medical Leave provisions. 

Delaware’s Healthy Delaware Families Act was passed in 2022 to establish a statewide Paid Family and Medical Leave (PFML) insurance program. 

The program officially started its funding phase on January 1, 2025, when employers and employees began contributing through payroll deductions. 

Effective January 1, 2026, eligible employees will be entitled to receive paid benefits under family and medical leave in Delaware. 

Duration of Leave: 

• Parental Leave: Up to 12 weeks of paid leave per year for bonding with new child 
• Medical Leave: Up to 6 of paid leave weeks in 24-month period for own serious health condition 
• Family Caregiving Leave: Up to 6 of paid leave weeks in 24-month period for family member’s serious health condition 
• Military Exigency Leave: Up to 6 weeks of paid leave in 24-month period 

Employer Size Requirements: 

• Employers with 10-24 employees: must provide parental leave only 
• Employers with 25+ employees: must provide all leave types 
• Employers with fewer than 10 employees: Exempt (may opt in) 

Eligibility Criteria: An employee is eligible if the employee has worked : 

• at least 12 months for employer 
• at least 1,250 hours in the previous 12 months. 

Usage of Leave – Eligible employees will be able to take job-protected paid leave for the following reasons: 

• their own serious health condition 
• bonding with a new child after birth, adoption, or foster placement 
• caring for a family member with a serious health condition 
• military-related exigencies (for example, deployment or related activities). 

Pay: An employee will be entitled to receive pay benefits from their employer. 

The program is funded by employer contributions. The Act allows the employer to require the employees to contribute up to 50% of the cost via payroll deduction. 

Notice Requirement: An employee must provide their employer with written notice of leave at least 30 days in advance. If providing 30 days’ notice is not practicable, the employee must give notice as soon as possible.  

The notice should include the reason for the leave (such as the employee’s own serious health condition, caring for a family member, bonding with a new child, or a military-related exigency), the expected start and end dates, and, if applicable, any intermittent or reduced leave schedule. 

Illinois: Blood and Organ Donation Leave Act 

Currently, the Blood and Organ Donation Leave Act allows eligible employees to take paid leave for blood donation or organs donation. 

Full-time employees who have worked for at least 6 months with an employer (with 51 or more employees) are qualified for paid blood and organ donation leave. 

Employees may take up to 1 hour every 56 days for blood donation, up to 2 hours (24 times a year) for platelet donation, and up to 10 days per 12 months for organ donation (30 days for State employees). 

Effective January 1, 2026, expands eligibility to include any participating employee or part-time employee shall be entitled to up to 10 days of paid organ donation leave in any 12-month period. 

Pay for Part-time employees- Part-time employees shall be paid at a rate equal to their average daily pay over the previous 60 days of employment during the leave period. 

Notice requirement– Both full-time and part-time employees must obtain employer approval before taking organ donation leave. 

Note: Paid blood donor leave remains available only to full-time employees. 

Illinois:  Nursing/Breastfeeding Leave 

Currently, Nursing mothers are entitled to receive unpaid break to express breast milk for up to one year after birth and a private space (not a bathroom) for that purpose. 

Effective January 1, 2026, an employer shall provide reasonable paid break time to an employee who needs to express breast milk for their nursing infant child each time the employee has the need to express milk for one year after the child’s birth.  

An employer shall compensate the employee during the break time at the employee’s regular rate of pay for nursing/breastfeeding time. 

The break time may run concurrently with any break time already provided to the employee.  An employer shall not require the employee to use paid leave during the break time or reduce the employee’s compensation during the break time in any other manner. 

Connecticut: Sick Leave Eligibility Expansion 

Currently, employers with 50 or more employees are required to provide paid sick leave. Employers with fewer employees may provide leave voluntarily or under separate contracts.  

Effective January 1, 2026, the eligibility threshold is lowered; employers with 11 or more employees must provide paid sick leave. 

Paid sick leave may be used for an employee’s own illness, preventive care, or to care for a family member, consistent with existing law. 

Oregon: Paid Sick Leave Expansion for Blood Donation 

Currently, an eligible employee is entitled to use their paid sick for the following reasons: 

• own or family member’s illness, injury, or health condition 
• medical appointments and preventive care 
• public health emergencies affecting school or childcare 
• care of a newly born, adopted or newly placed foster child (under 18 years old), or a child over 18 with a mental or physical disability who is incapable of self-care within 12 months after birth or placement 
• certain safe leave situations (domestic violence, harassment, sexual assault, or stalking, as well as related activities such as seeking medical treatment, counseling, legal assistance, or relocating for safety.) 
• bereavement Leave (including attending a funeral or memorial service, making arrangements, or grieving the death of a family member.) 
• employees may donate accrued sick time to a coworker if the employer’s policy allows it. 

Employees accrue 1 hour of sick leave per 30 hours worked (up to 40 hours annually). 

Effective January 1, 2026, eligible employees will be entitled to use their paid sick for blood donation.  

The law is amended to add blood donation as a qualifying reason under the state’s paid sick leave law.  

Note: This is NOT an additional leave of entitlement. Employees use their existing accrued sick time for blood donation purposes. 

California: Training & Education Records  

Currently, employers allow current and former employees to inspect and receive copies of personnel records relating to the employee’s performance or grievances. This currently includes performance evaluations, written warnings, performance improvement plans, attendance records, and investigation summaries. Employers must respond to written requests within 30 calendar days. 

Effective January 1,2026, the definition of “personnel records” will expand to explicitly include education and training records: 

Employers shall include the following documents under education or training records: 

• employee’s name 
• name of the trainer 
• duration and date of the training 
• core competencies of the training (including equipment or software skills) 
• resulting certification or qualification 

 Proposed Amendment: Illinois Neonatal Intensive Care Leave Act 

Effective June 1, 2026, employers with 16 or more employees must provide job-protected unpaid leave for employees whose child is a patient in a neonatal intensive care unit (NICU). Employers with 16–50 employees must allow up to 10 days of unpaid leave, while employers with 51 or more employees must allow up to 20 days. 

Takeaway: Employers in the respective states should begin reviewing policies in relation to the above-mentioned provisions and take action to ensure compliance with the new changes in the law. 

New Zealand: Proposed Reforms to the Holidays Act 2003 

The New Zealand Government has announced a comprehensive reform of the Holidays Act 2003, intended to simplify the calculation of leave entitlements and promote greater fairness, transparency, and consistency across various forms of employment. The proposed amendments will introduce substantial changes to the manner in which annual, sick, and other categories of leave are accrued, taken, and compensated. 

A transition period of 24 months has been proposed following the enactment of the Bill. allowing employers and payroll providers adequate time to implement the new requirements. The Bill is expected to be passed by early 2026, with the revised Holidays Act likely to take effect around early 2028, depending on when the legislation is passed. 

Key changes are as follows:  

Annual Leave  

Currently, employees are entitled to four weeks of annual leave after completing 12 months of continuous employment. Leave is granted as a lump-sum entitlement rather than accruing progressively throughout the year. 

Entitlement does not accrue during periods of unpaid leave (except where the absence is due to sick leave, bereavement leave, or family violence leave).

Employees are permitted to cash up one week of annual leave in each 12-month entitlement period. 

Proposed Changes 

Under the reform, annual leave will accrue progressively from day one of employment based on actual hours worked at a rate of 0.0769 hours per hour worked (equivalent to 4/52). 

Key details include: 

• Leave will continue to accrue during periods of paid leave, parental leave, and jury or volunteer service, but will not accrue during unpaid leave or while the employee is receiving accident compensation. 
• Leave balances will be recorded in hours instead of weeks and will remain fixed even if the employee’s contracted hours change. 
• Leave may be taken in hourly increments, allowing alignment with the employee’s rostered or contracted hours. 
• Employees may request to cash up to 25% of their accrued annual leave balance, as at their last employment anniversary, in any 12-month period (an increase from the current limit of one week). 

Sick Leave 

Currently, employees become entitled to 10 working days of paid sick leave after completing 6 months of continuous employment with the same employer. This entitlement renews every 12 months, with a maximum accumulation of 20 days, and is currently taken in full-day increments. 

Proposed Changes 

Under the new framework, sick leave will accrue from day one at a rate of 0.0385 hours per hour worked (2/52), up to a maximum cap of 160 hours. 

• Accrual will continue during the same unpaid and paid periods applicable to annual leave. 
• Sick leave may be taken in hourly increments, introducing greater flexibility for part-time, variable-hours, and casual employees. 

Bereavement and Family Violence Leave 

Currently, employees are entitled to bereavement leave and family violence leave only after completing 6 months of continuous employment. Bereavement and family violence leave must be taken in full-day entitlements. 

Proposed Changes 

Under the reform, these entitlements will apply from the first day of employment. Employees may take part-day leave for these purposes and may also use it on the same day as sick leave if circumstances overlap.  

Public Holidays 

Currently, employees are entitled to paid public holidays and alternative holidays only on days that qualify as “Otherwise Working Days” (OWDs). 

“An OWD is defined as a day the employee would normally have worked had the public holiday, sick leave, or other leave not occurred.” 

Proposed Changes 

Under the reform a new statutory OWD test will be introduced for employees who do not have fixed working patterns. 

A day will be considered an OWD if the employee has worked that specific day of the week in at least 7 of the preceding 13 weeks.  

Alternative Holidays 

Currently, employees who work on a public holiday that is an OWD are currently entitled to one full alternative day off, regardless of the number of hours worked. 

The alternative day must be taken on another OWD and may be cashed up after 12 months if unused. 

Proposed Changes 

Under the reform, employees will accrue alternative holidays on an hour-for-hour (1:1) basis for every hour worked (or required to work, if called in) on a public holiday. 

These hours can be taken on any day that could otherwise have been worked under the employee’s agreement and may be cashed up at any time.  

Leave Payments 

Currently, calculating leave payments involves comparing various pay averages (such as ordinary weekly pay and average weekly earnings). 

This process often results in administrative complexity and inconsistent outcomes. Employees taking annual leave soon after parental or volunteer leave may also receive reduced pay due to override provisions. 

Proposed Changes 

Under the new system, all leave types will be paid at a consistent hourly leave pay rate determined by: 

• The base hourly pay applicable on the day of leave and include the average of any piece-rate earnings, where relevant; 
• Fixed allowances will continue to be paid in full during leave; and 
• Annual leave taken immediately following parental or volunteer leave will be paid at the employee’s normal rate, addressing the current pay disadvantage. 

Leave Compensation Payments 

Currently, employers and employees may agree to a “pay-as-you-go” arrangement, where 8% of gross earnings is paid instead of accruing annual leave. This applies mainly to irregular or fixed-term employment under 12 months. 

Proposed Changes 

The reform replaces the existing model with a Leave Compensation Payment (LCP) equal to 12.5% of the employee’s ordinary hourly pay rate. 
This payment will apply: 

• To all hours worked by casual employees, and 
• To additional hours worked by other employees (unless already covered by salary). 
• This replaces the accrual of annual and sick leave for those specific hours. 
• Fixed-term employees, however, will now accrue leave from day one, removing reliance on pay-as-you-go arrangements and aligning their entitlements with those of permanent employees.