With no ruling yet from the Missouri Supreme Court in the litigation challenging Proposition A, Missouri’s new paid sick leave law is set to go into effect on May 1, 2025. Employers with at least one employee in Missouri should take immediate action to ensure compliance with this deadline.

As outlined in our previous Client Alert, the law imposes significant new obligations on employers with employees in Missouri. Employers with existing paid time off (PTO) or paid-sick leave policies—including those offering unlimited leave—should not assume their policies automatically comply with the new law. We strongly recommend employers seek legal counsel to review and, if necessary, update their current policies.

Overview of Requirements Effective May 1, 2025

• Accrual: Employees begin accruing one hour of paid sick leave for every 30 hours worked. Overtime-exempt employees are presumed to work 40 hours per week for accrual purposes.
• Use Limits: Employers may cap an employee’s use of paid sick leave at 56 hours per calendar year, or 40 hours for employers with fewer than 15 employees.
• Carryover: Employees are entitled to carry over up to 80 hours of unused paid-sick leave into the following year.
• Frontloading Option: Employers may frontload at the start of the year the full amount of expected annual sick leave—69.33 hours for an employee working 40 hours per week. If an employer chooses this option, it may elect to pay out unused time at year-end instead of allowing carryover. However, employers may not force a “cash-out” without also frontloading leave for the new year.
• Permissible Reasons: Employees can utilize their paid sick leave for a wide range of qualifying reasons, including:
• for their own physical or mental illness, injury, or health condition;
• to care for a family member experiencing similar mental or physical health issues;
• to remain at home during public-health emergencies that lead to business closures;
• to care for a child whose school or care facility has closed due to public-health emergency; and
• to address domestic violence, sexual assault, or stalking.

Notice Requirements Already in Effect

Employers were required to take two steps by April 15, 2025:

1. Provide written notice to all Missouri employees outlining their paid-sick leave rights under Proposition A; and
2. Display the poster issued by the Missouri Department of Labor in the employers workplace.

Failure to comply with these notice and posting requirements could result in significant liability. A “willful” violation could result in fines of up to $500 per day, with each day counted as a separate offense.

The required notice and poster—both available here—must be printed on a single sheet (minimum size 8.5 x 11 inches) in no less than 14-point font. We interpret this to mean that electronic notice alone is likely insufficient.

Accordingly, we recommend employers, if they have not done so already, immediately distribute printed copies of the notice to all Missouri employees and display the poster in a common, visible area, such as a breakroom.

Legislative Developments

The Missouri House has passed a bill that would repeal the sick-leave provisions of Proposition A. However, the House voted against adding an emergency clause to the bill. Without an emergency clause, the bill will not take effect immediately upon the Governor’s signature. Instead, if enacted, the repeal of the paid-sick leave obligations will not take effect until August 28, 2025, creating a temporary period during which employers must still comply with Proposition A’s sick-leave requirements. While the bill has since moved to the Senate, progress was stalled last week by a Democrat-led filibuster that successfully blocked a vote on the bill. The bill is now on the Senate’s informal calendar and may be raised for a vote again before the legislative session ends on May 16, 2025.

Bottom Line for Employers

Given the legal challenges and ongoing uncertainty surrounding the law, some employers may have assumed it would not go into effect. That assumption could now result in potential liability. We recommend employers act promptly to comply with the May 1 deadline and consult legal counsel to ensure their sick leave policies are compliant with the new law.