On April 10, 2025, the Cook County Board of Commissioners approved further revisions to the Commission on Human Rights’ regulations implementing the county’s paid leave ordinance. Many private employers will welcome these clarifications.

No Accrual of Paid Leave When Using Paid Leave: The paid leave ordinance requires statutory paid leave to accrue based on “hours worked.” Originally, the rules had stated that employers were required to allow employees to accrue statutory paid leave when using statutory paid leave. The revised rules revert to the ordinance’s “hours worked” standard.

Pay Date When Paid Leave Used: The ordinance is silent as to when statutory paid leave must be paid after it is used. The rules initially required payment by the payday for the pay period during which the employee used such leave. Now, however, payment need not be made until the payday for the pay period after the pay period during which the employee used leave.

Additional Benefits When Using Paid Leave: Previously, the rules required that, if an employer would compensate an employee for regular work with additional benefits (e.g., paid leave accrual, seniority or health benefits), the employer also had to offer those additional benefits to employees when they use statutory paid leave. As revised, the rules say that if an employer elects to offer additional benefits when employees use statutory paid leave (paid leave accrual, seniority or health benefits), they must do so in the same manner and...

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