By: HUB's Absence Management Team

On May 14, 2025, the Missouri Legislature passed House Bill 567, which repeals the paid sick leave provisions of Proposition A that were set to take effect on May 1, 2025. This update outlines the bill's impact on employer obligations, implementation timeline, and next steps for compliance.

Legislative Outcome

The Missouri House of Representatives and Senate have passed House Bill 567 (HB 567). The bill makes two significant changes to Missouri employment law:

  • Repeal of Paid Sick Leave Requirements: HB 567 completely repeals the paid sick leave provisions that were established by voter-approved Proposition A in November 2024.
  • Minimum Wage Changes: The bill maintains the current minimum wage of $13.75 for 2025 and the scheduled increase to $15.00 per hour on January 1, 2026, but eliminates future annual increases that would have been based on changes to the Consumer Price Index.

Effective Date

HB 567 will take effect on August 28, 2025, as it did not pass with an emergency clause. This creates a transitional period where employers must still comply with Proposition A's paid sick leave requirements until the repeal takes effect.

Current Employer Obligations

From now until August 28, 2025, employers must continue to:

  • Comply with the paid sick leave accrual and usage requirements as outlined in Proposition A (1 hour of paid sick time for every 30 hours worked)
  • Maintain appropriate records regarding earned paid sick time hours and usage for the required three-year period
  • Honor employee requests to use accrued sick leave for permissible purposes under the law
  • Ensure proper payment of sick leave at appropriate rates based on employee classification

Transitional Considerations

Documentation and Policy Updates

  • Employers should document all sick leave accrued and used by employees during the May 1 - August 28, 2025 period
  • Consider developing a policy regarding what will happen to unused accrued sick leave after August 28, 2025 (e.g., payout, conversion to PTO, or discontinuation)

Communications to Employees

  • Prepare communications to inform employees about the upcoming changes once HB 567 goes into effect
  • Consider sending an initial notice now about the transitional period and a follow-up communication closer to August 28, 2025

System Modifications

  • Modify timekeeping and payroll systems to suspend automatic sick leave accrual after August 28, 2025
  • Ensure proper accounting for any unused sick leave balances after the repeal date

Recommended Next Steps

  • Immediate Compliance: Continue to comply with Proposition A's requirements until August 28, 2025
  • Policy Review: Review your existing PTO or sick leave policies to determine whether to:
    • Return to pre-Proposition A policies after August 28, 2025
    • Maintain any changes previously made to comply with Proposition A
  • Communication Plan: Develop a communication strategy to inform employees about:
    • Current sick leave availability and usage rights until August 28
    • What will happen to accrued, unused sick leave after August 28
    • Any changes to company policies after the repeal takes effect
  • Documentation: Maintain all required documentation regarding sick leave accrual and usage during the May 1 - August 28 period to protect against potential claims

The previously released bulleting regarding Proposition A is provided below for reference.

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.

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.