Countdown to Minnesota Paid Leave: Employer Steps to Take
In May 2023, the State of Minnesota enacted paid family and medical leave called Minnesota Paid Leave. While the majority of the law’s requirements, including payroll contributions and the paid leave benefits, do not begin until January 2026, employers subject to the law need to act in Fall 2024 to remain compliant with the law.
Covered Employers
Most employers with employees in Minnesota are covered by Minnesota Paid Leave. The exceptions are the federal government and self-employed individuals providing their own paid family and medical leave benefits. There is no exception for small employers, though employers with 30 or fewer employees may be eligible for reduced premiums and grants.
Employer Responsibilities
Quarterly Wage Report Submissions
Employers must submit quarterly wage reports which will be used to determine the amount of premiums due, and the benefit amount provided to employees. The first wage report is due October 31, 2024, for the time between July 1, 2024, and September 30, 2024. Failure to complete the wage reporting may lead to monetary penalties.
Minnesota Paid Leave will use the existing Unemployment Insurance program to collect the required wage report. Organizations already using the Unemployment Insurance program will automatically have their Unemployment Insurance accounts transferred to a joint Unemployment Insurance and Paid Leave account. Employers not covered by the Unemployment Insurance program will need to register for a Paid Leave Only account through the Unemployment Insurance program to submit the required reporting. More information on the Minnesota Unemployment Insurance program is available here.
Required Employee Notice
In December 2025 employers must provide their employees with a notice informing them about Minnesota Paid Leave. A model notice is being developed to be used for this purpose. The notice must then be provided to new employees within 30 days of beginning employment.
Consider a Private Plan
Employers may opt-out of participating in the Minnesota Paid Leave program if they offer the same or better benefits through a private plan. Employers may want to assess whether providing paid family and medical benefits through a private plan makes more sense than participating in the state plan.
Deductions Begin in 2026
Employers should ensure they are ready to begin payroll deductions to fund Minnesota Paid Leave in January 2026.
Key Takeaways
Employers with employees in Minnesota would be well served to review their obligations under Minnesota Paid Leave. While the majority of the law’s requirements begin in 2026, employers’ obligations begin in Fall 2024.
The information provided is a summary of laws and regulations relating to employee benefit plan compliance. This information should not be construed as legal advice. In all cases, employers should consult with their own legal counsel.
