Real World Impact: Effective July 2, 2025, New York City’s Department of Consumer and Worker Protection will amend its implementing rules to the City’s Earned Safe and Sick Time Act to include the City’s own version of New York State’s paid prenatal leave (“PPL”) obligations for employers. Much of the City’s rules will merely duplicate the requirements already mandated by State law. However, employers should be aware that the City’s version will impose some additional responsibilities.
New Reporting Obligations:
Unlike the State’s PPL requirements, the City’s rules will require employers to furnish specific written payroll disclosures to their employees. Specifically, for each pay period that an employee uses PPL, the employer will need to inform the employee on either (a) a pay stub or (b) a separate written document, of two things: (1) the amount of PPL used during that pay period; and (2) the total remaining balance of PPL available for use out of the twenty hours allotted per 52-week period. When calculating the remaining balance of PPL, employers must be mindful that the 52-week period begins when an employee first uses PPL—not at the beginning of the year.
The Bottom Line
Employers in New York City will already be complying with much of the City’s incoming PPL requirements through their current policies tailored to follow existing State law. However, employers will need to notify applicable employees in writing of their recent PPL usage and remaining balance.
If you have any questions regarding this Alert, please contact the Alert’s authors, Gregory Reilly, partner in our New York City office at greilly@fordharrison.com, or Steven Balken, associate in our New York City office at sbalken@fordharrison.com. Of course, you can also contact the FordHarrison attorney with whom you usually work.