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....

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