Minnesota’s paid leave program goes into effect January 1, 2026, which will be here sooner than you think and there are important deadlines to be aware of. Employers who have not yet done so should:
- Provide notice to employees
- Consider whether to adopt an equivalent plan
- Review their other policies to ensure alignment with the new state program
What Does the Program Provide?
Like the paid leave programs in several other states, Minnesota’s paid leave program seeks to provide partial wage replacement and job protection to employees when they need time off to:
- Recuperate from major medical issues
- Care for ill family members
- Bond with a new child
- Support family members called to activity duty
Employees may qualify for:
- Up to 12 weeks of family or medical leave per benefit year
- Up to a maximum of 20 weeks if family and medical leave are both needed in the same year
Who Must Participate?
Almost all businesses with employees in Minnesota are required to participate in the state program, unless they have opted out with an approved equivalent plan. Equivalent plans (which can be either administered by the employer or through an insurance company) must offer the same or better coverage than the state program and must not cost employees more than they would be required to contribute under the state plan.
Whether an employer should participate in the state program or seek to opt out depends on the workforce and business needs. If you are interested in opting out but have not yet requested approval of an equivalent plan, it’s not too late to do so, but be mindful of the deadlines below.
Key Deadlines
- November 10, 2025 – Deadline by which employers must submit their proposed equivalent plan for state approval. While this deadline has passed, it is not too late to get your equivalent plan approved by the state, but you will need to wait until at least Q2 2026 for it to go into effect and will need to contribute to the state plan until that time.
- December 1, 2025 – Deadline by which employers must individually notify employees of Minnesota’s paid leave law and their premium obligations. Employers are required to obtain employee acknowledgment of the notice to be effective, and a workplace poster must also be posted. If you missed the notice deadline, you should make a good-faith effort to notify employees as soon as possible so that employees are aware of the upcoming paid leave law before January 1. A model notice and the required posters can be found here.
- December 31, 2025 – Suggested deadline by which employers should submit their equivalent plan to the state for approval if the November deadline was missed and the employer is seeking to implement the plan on April 1, 2026. Learn more about submitting equivalent plans for approval here.
- January 1, 2026 – Paid Leave Law begins and employers and employees must start contributing to the state program via payroll deductions unless the employer has an approved equivalent plan. Eligible employees may begin applying for paid leave benefits on this date, and in some cases of child bonding leave, before this date.
- April 30, 2026 – Deadline by which employers must submit wage detail reports and premium payments based on wages paid from January 1, 2026 to March 31, 2026. Reporting and payments will thereafter be due quarterly. Learn more about employer responsibilities with wage reporting and premiums here.
Why Compliance Matters
While Minnesota is the 13th state to implement state-run paid leave of this type, its program is among the nation’s most ambitious. At the same time, Minnesota’s Department of Labor and Industry has been cracking down on compliance with employee wage and hour and leave laws, as well as employer hiring requirements.
It is more important than ever that employers with Minnesota-based employees approach such employment obligations carefully. Employers may also wish to revisit their existing leave policies as well as any short-term disability leave insurance policies, to ensure alignment with the new law.
Need Assistance?
Based on the feedback we have heard so far, many employers are finding the law’s requirements tricky to navigate, and the equivalent plan approval process can be onerous. Please reach out to Emily Atmore or your Stoel Rives attorney with any questions about navigating Minnesota’s paid leave law.