Labor & Employment Law Update

Missouri’s paid sick time law, Proposition A, is scheduled to go into effect on May 1, 2025.

While the constitutionality of Proposition A is currently being challenged under a state lawsuit before Missouri’s Supreme Court and Missouri’s General Assembly is considering legislation to repeal the mandate altogether, the paid sick time requirements are still on course to take effect May 1.

Importantly, Proposition A requires Missouri employers to provide employees with written notice of the employer’s earned paid sick time policy by April 15, 2025—which is quickly approaching. Accordingly, Missouri employers must decide now what they may need or want to do concerning the upcoming deadlines.

On November 5, 2024, Missouri voters approved Proposition A, which provided for increases to Missouri’s minimum wage and established a paid sick time mandate for most private employers in Missouri (except for retail and service businesses whose annual gross volume sales made or business done is less than $500,000 dollars). On January 1, 2025, Missouri’s minimum wage increased to $13.75/hour in accordance with Proposition A, and is set to increase again to $15/hour on January 1, 2026.

Beginning May 1, covered employees will be entitled to earn and use up to 56 hours of paid sick time per year (if the employer has 15 or more employees) or up to 40 hours per year (if the employer has fewer than 15 employees). Covered employees will accrue a minimum of one hour of paid sick time for every 30 hours worked without a cap on the accrual amount.

There are many unanswered questions that should be addressed by the state of Missouri in the coming weeks and months. Be mindful that Proposition A is currently being challenged in Missouri’s Supreme Court. In addition, legislation (House Bill 567) to repeal the paid sick time mandate was passed by the Missouri House of Representatives on March 13 and is currently being considered by the State Senate. If signed into law, it will repeal the paid sick time mandate effective August 28, 2025—after the April 15 and May 1 compliance deadlines.

As it stands, Proposition A is set to take effect as scheduled and Missouri employers must decide how they are going to address the April 15 notice deadline and May 1 deadline to implement a paid sick time policy for covered employees. Also, keep in mind that Missouri employers who provide employees with access to earn and use paid leave that meet or exceed Proposition A’s mandates should be fine.

It is critical for Missouri employers to consult with experienced labor and employment law counsel to navigate this process. Without a decision to the contrary from the Missouri Supreme Court or legislation to repeal the paid sick time mandate, Missouri employers must prepare for all outcomes. Be assured, we will provide updates as they develop.

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