By: HUB's Absence Management Team

This bulletin has been updated to reflect the passage of HB 567, which, upon the Governor's signature, repeals Missouri's Paid Sick Leave requirements effective August 28, 2025.

On November 5, 2024, Missouri voters approved Proposition A, establishing a new statewide paid sick leave program effective as of May 1, 2025. This bulletin outlines key provisions of the law, current legal challenges, and essential next steps for employers.

Overview

The Missouri Department of Labor's (DOL) Wage and Hour Division has established new statewide paid sick leave requirements as part of Proposition A. While this law faces legal challenges and potential legislative changes, employers should prepare for implementation as scheduled. The law requires most private employers to provide earned paid sick time to eligible employees effective May 1, 2025.

Missouri Paid Sick Leave Requirements

Covered Employers

All private employers with annual gross volume sales or business done of $500,000 or more are required to provide earned paid sick time benefits. Public employers (federal and state government, political subdivisions, agencies, school districts, and public higher education institutions) are exempt.

Accrual and Usage

  • Employees accrue 1 hour of paid sick time for every 30 hours worked
  • Employers with 15+ employees: Employees may use up to 56 hours per year
  • Employers with fewer than 15 employees: Employees may use up to 40 hours per year
  • Up to 80 hours of unused sick time can carry over to the following year
  • Alternatively, employers may pay out unused time at year end and provide the full amount (“front load”) at the beginning of the following year
  • Accrual under the law began on May 1, 2025, or at the commencement of employment, whichever is later

Permissible Uses

Employees may use earned paid sick time for:

  • Physical or mental illness, injury, or health condition for themselves or family members
  • Medical care, diagnosis, treatment, or preventative medical services
  • Workplace or school closures due to public health emergencies
  • Matters related to domestic violence, sexual assault, or stalking

Rate of Pay

  • Regular hourly employees: Their standard hourly rate with the same benefits
  • Multiple hourly rates: Either the wage for exact hours that would have been worked or the weighted average of all hourly rates
  • Salaried employees: Total wages from previous pay period divided by total hours worked
  • Tipped employees: Regular hourly rate or state minimum wage, whichever is higher (tips cannot be deducted)

Record Keeping

Employers must maintain documentation regarding earned paid sick time hours and usage for three years.

Penalties for Non-Compliance

Willful failure to comply is classified as a class C misdemeanor, with each day of violation constituting a separate offense. The law also creates a private right of action for employees.

Current Legal Challenges

The law currently faces one legal challenge:

  • House Bill (HB) 567 would eliminate the paid sick leave components of the law

With the legislative session due to end on May 16th, legislators have a short amount of time to present a substitute bill for a vote.

Next Steps

Employers should take the following actions to ensure compliance with Missouri Paid Sick Leave requirements as currently written:

  • Provide written notice to all employees on a single piece of 8.5 x 11 paper in at least 14-point font
  • Post the required notice in a conspicuous and accessible place
  • The Missouri DOL has released official notice and poster documents available on their website
  • Review and update paid time off policies to ensure compliance with accrual and usage requirements
  • Establish systems to track employee accrual and usage of sick time
  • Train managers and HR personnel on the new requirements
  • Ensure payroll systems can properly calculate sick time pay rates for different employee classifications

Consider Existing Policies

  • Employers with existing paid time off policies that meet or exceed the requirements of the law are not required to provide additional paid sick time
  • Ensure existing policies permit use for all purposes outlined in the law

If you have any questions about implementing Missouri's paid sick leave requirements or need assistance with policy updates, please contact your Human Resources representative. We will continue to monitor legal challenges and provide updates as the situation develops. View more Workforce Absence Management updates in our WAM Bulletins page.

NOTICE OF DISCLAIMER
Neither Hub International Limited nor any of its affiliated companies is a law or accounting firm, and therefore they cannot provide legal or tax advice. The information herein is provided for general information only and is not intended to constitute legal or tax advice as to an organization’s specific circumstances. You should consult an attorney, accountant, or other legal or tax professional regarding the application of the general information provided here to your organization’s specific situation in light of your organization’s particular needs.