Seyfarth Synopsis: West Hollywood, California enacted a general, non-COVID paid time off mandate with a minimum wage component. Effective January 1, 2022 for “hotel employers” and July 1, 2022 for other employers, this mandate includes compensated time off and uncompensated time off components. Various aspects of the city’s leave mandate make it an outlier as compared to the California State Paid Sick Leave (“PSL”) Law and other municipal paid sick leave ordinances in California.[1] On May 16, 2022, West Hollywood amended the Ordinance. The city also has recently released regulations, model notices, and other administrative guidance in advance of the July 1, 2022 effective date that impacts non-hotel employers.

On November 15, 2021, West Hollywood, California[2] enacted an Ordinance requiring employers to allow accrual of up to 96 compensated hours per year for sick leave, vacation or personal necessity to full-time employees, and instituting a number of other requirements.[3] On May 16, 2022, West Hollywood amended the Ordinance and recently released regulations and administrative materials, such as required posters regarding the new minimum wage and the time off components.

Here are the key components of the time off mandates:

• Different Effective Dates for Hotel Versus General Employers: For hotel employers, the Ordinance took effect on January 1, 2022. For all other employers, the Ordinance takes effect on July 1, 2022.
• Definition of “Employee”: The Ordinance...

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