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Thursday, April 30, 2026

New Illinois Leave Law: Paid Leave for Any Reason - Mintz

Illinois will become the third state (including Nevada and Maine) to mandate employers to provide employees with paid time off for any reason. The new law, which we summarize below, will become effective in 2024.

The Law Reaches Most Employers, But Does Exempt Those Subject to Local Leave Ordinances.

The Act covers all individual, public, and private employers that have one or more employees in Illinois, except certain federal and state employers.

Notably, the Act also exempts employers that are covered by a “municipal or county ordinance that is in effect on the effective date of this act that requires employers to give any form of paid leave, including paid sick leave or paid leave.” Thus, the law would not apply to employers subject to the Cook County or Chicago paid sick leave ordinances. Further guidance will need to be issued to help employers otherwise subject to this exemption understand whether and how the new leave requirements may apply when they utilize a hybrid working model that has employees working inside and outside exempted jurisdictions.

The Law Covers Most Employees, Although Several Exceptions Apply.

The Act covers “all employees. . . in this state” and “shall include any individual permitted to work by an employer in an occupation,” but it does contain certain specific exceptions (e.g. certain unionized workers). Further guidance will also need to be issued in the remote work context to understand when an employee is considered working in Illinois.

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