As a reminder, Michigan’s Earned Sick Time Act (ESTA) will soon cover nearly all employers. Starting October 1, 2025, businesses with 10 or fewer workers will be expected to provide paid sick time, closing the gap that left smaller employers temporarily exempt. Larger organizations have already been operating under the law since February 21, 2025, and a deeper overview of those requirements can be found in our earlier client alert.

Determining Employer Size

Whether you count as a “small” or “large” employer isn’t based solely on your Michigan workforce. Instead, headcount includes all employees nationwide—full-time, part-time, temporary staff, and even individuals provided by staffing agencies. If an employer has 11 or more workers for at least 20 workweeks in the current or prior calendar year, it is considered a “large” employer and must stay in that category through the end of the following year.

What Employees Receive

Workers in small organizations will be guaranteed up to 40 hours of paid sick time per year. Businesses can provide that benefit in two different ways:

• Accrual model – Sick time accrues at the rate of one (1) hour for every 30 hours worked. Employers can limit both annual use and rollover to 40 hours. Accrual begins October 1, 2025 (or upon hire, if hired after that date). A waiting period of up to 120 days can be applied to new hires, although time continues to accrue during the waiting period.
• Frontload model – Instead of tracking accrual, employers...

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