Chicago Passes Sweeping Paid Leave Ordinance

The city of Chicago approved the Chicago Paid Leave and Paid Sick and Safe Leave Ordinance (the ordinance) on November 9, 2023, providing all employees working in the city with up to five annual days of paid leave that can be used for any purpose (paid leave) and five annual days of paid sick leave that can be used for specified purposes (paid sick leave). The ordinance, which takes effect on December 31, 2023, significantly expands paid leave requirements for Chicago employers and includes some of the harshest penalties in the country for violations of paid leave provisions. This Update provides a synopsis of the new ordinance's stringent requirements.

Who Is Covered?

As a threshold matter, the ordinance broadly defines "Employer" as "a person who gainfully employs at least one" employee (emphasis added). The ordinance applies to any "Covered Employee," defined as any employee who, during "any particular two-week period, performs at least two hours of work while