10 | 2025 Employment Laws on the Horizon © Seyfarth Shaw LLP Hours of Work County, imposes various requirements on covered Retail Employers with 300 or more employees globally, as follows: (1) before hiring a person for a position that will qualify the person as a Retail Employee, as defined in the Ordinance, provide a written, good faith estimate of the work schedule in the person’s primary language that includes the Notice of Retail Employee’s Workweek Rights; (2) upon a current Retail Employee’s request, provide a good faith estimate of work in their primary language within 10 days of the request; (3) provide Retail Employees with notice of their work schedule at least 14 days before the start of the work period by posting the schedule in a conspicuous and accessible location or transmitting it electronically, with Retail Employees having a right to decline any hours, shift, or work location changes not included in the work schedule; (4) have documented consent from the impacted Retail Employees if the employer changes the work schedule after the 14-day period; (5) pay consenting Retail Employees 1 additional hour of pay at their regular rate of pay for each change to a scheduled date, time, or location that results in no lost time or results in additional work time that exceeds 15 minutes; (6) pay Retail Employees one-half of their regular rate of pay for the time the employee does not work when the employer (a) changes the start or end time of a shift resulting in a loss of more than 15 minutes; (b) subtracts time from a shift before or after the employee reports to work; (c) changes the date of a shift; (d) cancels a shift; or (e) schedules the employee for an on-call shift and the employee is not called in (subject to limited exceptions when the pay is not required); (7) before hiring a new Retail Employee or using a contractor, temporary service, or staffing agency to perform work, first offering the work to current Retail Employees if (a) one or more of the current Retail Employees is qualified to do the work; and (b) the additional work hours would not result in the payment of overtime; (8) post a notice; and (9) keep specific records. (Ordinance; Seyfarth Post) Wage & Expense, etc. Earned Wage Access Services CA (Eff. 2/25) – Income-based advances (i.e., EWA) treated as loans and are subject to the CA Fair Lending law. By February 15, 2025, EWA providers must register and obtain a license to offer such services. Unlike the proposed CFPB regulations, the rule does not require companies to provide CA users with an APR. (Announcement; Final Text) Overtime & Premium Pay MN (Eff/ 1/1/25) – MN published a template that may be used to comply with the new nursing home holiday pay notice requirement. (Posting) WA (Eff. 1/1/25) – Beginning January 1, 2025, for purposes of mandatory overtime, the definition of health care facility “employee” is broadened to include any person employed by a health care facility that is involved in direct patient care activities or clinical services and receives an hourly wage or is covered by a CBA. (H.B. 2061) Pay Statements CO (Eff. 1/1/25 & 2/1/25) – Delivery network companies (Eff. 1/1/25) and transportation network companies (Eff. 2/1/25) required to provide drivers with electronic payment disclosures after completing a transportation task. (H.B. 24-1129 and S.B. 24-75) IL (Eff. 6/1/25) – Employers must maintain pay stub records for 3 years. For employers who provide electronic pay stubs that employees cannot access for a year following their separation, they must offer to provide,
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