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Chicago Delays Implementation of and Amends Its Paid Time Off Ordinance


Elizabeth N. Hall, Cara J. Ottenweller and Carissa A. Townsend


Submitted by Firm:
Vedder Price P.C.
Firm Contacts:
Alex Weinstein
Article Type:
Legal Update

On December 13, 2023, the Chicago City Council voted to delay the implementation of, and amended, the previously approved Chicago Paid Leave and Paid Sick and Safe Leave Ordinance (the “Amendment”).  We wrote about the initial form of the Ordinance here.  The Amendment will go into effect on July 1, 2024.  Key differences between the original Ordinance and the Amendment are outlined below.

Modified definition of Covered Employee.  The definition of “Covered Employee” is more narrow than initially provided, and, per the Amendment, will include only employees who physically work within the City’s geographical boundaries for at least 80 hours during any 120-day period.  Notably, once an employee qualifies as a Covered Employee, the employee will remain a Covered Employee through the date on which employment with the covered employer ends.

Modified payout dates for Paid Leave.  Under the Amendment, many covered employers will still need to pay out unused and accrued Paid Leave (but not Paid Sick Leave) following termination, resignation, retirement, other separation or transfer outside of the City’s geographic limits.  However, the payout obligation will now not be triggered for any employer until July 1, 2025, at the earliest. 

New rules for private causes of action relating to Paid Leave.  Covered Employees will not be able to bring a private cause of action for violations of the rules relating to Paid Leave until July 1, 2025.  Per the Amendment, a Covered Employee may initiate a civil action only after (A) an alleged violation occurs; and (B) the payday for the next regular payroll period or 16 days after the alleged violation occurred passes, whichever is the shorter period. The waiting period requirements will expire on July 1, 2026.

What are the practical impacts of the Amendment?

Employers must continue to be mindful of their obligations to comply with Chicago’s existing Paid Sick Leave Ordinance until the Amendment goes into effect on July 1, 2024.  Employers are encouraged to work with legal counsel to ensure that their policies are compliant in advance of the July 1, 2024 deadline.

If you have any questions about this article, please contact Elizabeth N. Hall at, Cara J. Ottenweller at, Carissa A. Townsend at or any other Vedder Price attorney with whom you have worked.