The Chicago City Council has passed an amendment to the new Paid Leave and Paid Sick and Safe Leave Ordinance that delays its effective date from December 31, 2023, to July 1, 2024.

The new effective date grants employers a much-needed window to determine its compliance obligations. Until then, Chicago employers will still be subject to the existing Paid Sick Leave ordinance. For details on the existing ordinance, see this HR Law blog post and an update on the ordinance.

As a refresher, the Chicago City Council passed the Paid Leave and Paid Sick and Safe Leave Ordinance on November 9, 2023. The Ordinance, which will replace the Paid Sick Leave Ordinance, requires employers to provide:

• Up to 40 hours of leave usable for any purpose and
• Up to 40 hours of leave for illness, injury or medical appointments.

(for more details on the new Ordinance, see this HR Law Blog post)

There is one other matter of note regarding the new Paid Leave/Sick Leave Ordinance. As we wrote in our original article, it was unclear whether “frontloading” of the required amount of paid sick leave would relieve the employer from the obligation of carrying over unused paid sick leave. The City of Chicago has now issued proposed regulations that make clear that frontloading each type of leave (paid leave and paid sick leave) relieves the employer from having to carry over such leave from year to year.