On November 15, 2021, West Hollywood, California enacted an ordinance that establishes a local minimum wage, requires employers to provide paid and unpaid leave benefits, and governs how businesses advertise and distribute service charges. For businesses with employees performing work in West Hollywood, this trifecta could present considerable legal compliance and operational challenges, which compound for those with employees throughout California, particularly if they operate in nearby cities like Los Angeles and Santa Monica, where similar (not identical) laws exist.

Operative Dates: Different requirements will apply on different dates.

• Service Charges: The ordinance does not expressly say when its service charge provisions become operative, so absent future guidance from the city, these should take effect when the law does, 30 days after its final passage: December 15, 2021.
• Minimum Wage: These provisions become operative for all covered employers on January 1, 2022, but, as we explain below, the minimum wage rates will differ based on the type of establishment / worker or (for the first two years) how many employees a business has.
• Paid & Unpaid Leave: These provisions become operative on January 1, 2022 for “hotel employers” and “hotel workers,” whereas, for other entities, July 1, 2022 will be the start date.

Covered Employers & Employees: Generally, the law covers all employers with covered employees, but certain aspects will phase in at different...

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