On November 3, the Illinois Department of Labor published its proposed rules for the much discussed (and complained about) Paid Leave for All Workers Act. Of particular note is the IDOL's comment under "General Provisions:"

"An employer who has a qualifying pre-existing paid leave policy in effect on January 1, 2024, is not required to modify the pre-existing paid leave policy."

"Qualifying pre-existing paid leave policy" is defined in the proposed rule as "a bona fide paid leave policy that an employer has enacted prior to January 1, 2024, that, in practice, allows all employees to take at least 40 hours of paid leave for any reason of the employee's choosing." Obviously, there's a lot to unpack in those few words, but it appears we're getting closer to some clarity around what – if anything – an Illinois employer needs to do get ready for the effective date of the Act.

You can read the proposed rule for yourself here:


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