Takeaways

• Chicago’s updated rules (effective 06.01.26) clarify key aspects of its Paid Leave and Paid Sick and Safe Leave Ordinance, including compliance options, certification rules, and limits on sick leave use.
• The updated rules expand and define permissible uses and confirm employers may use a combined PTO policy if it meets accrual, carryover, and other requirements.
• They also address areas such as discipline for misuse and joint employer and successor liability.

• Summary of Changes

Article

Chicago’s Paid Leave and Paid Sick and Safe Leave Ordinance requires employers to provide covered employees with up to 40 hours of Paid Leave that can be used for any reason and up to 40 hours of Paid Sick Leave annually. The City of Chicago’s updated Paid Leave and Paid Sick and Safe Leave Ordinance rules provide employers with important clarification effective June 1, 2026.

Childcare Closures

The Ordinance allows covered employees to take Paid Sick Leave when their child’s “place of care” has an unscheduled closure. The updated rules clarify that a “place of care” includes informal caretaking arrangements (e.g., home babysitters and family members who supervise children).

Combined Paid Leave and Paid Sick Leave Policies

The updated rules explicitly authorize employers to maintain a single bank of paid time off (PTO) in lieu of maintaining separate banks so long as the employer’s policy allows covered employees to accrue up to 80 hours of paid time off and meets all other...

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