New York City employers should take note: final rules for the City’s Protected Time Off Law are now in effect, bringing important updates for HR, payroll, and compliance teams. Cozen O’Connor recently published a timely alert on the New York City Department of Consumer and Worker Protection’s final rules implementing the City’s February 2026 amendments to the Earned Safe and Sick Time Act, now referred to as the Protected Time Off Law (PTOL). The final rules took effect July 23, 2026 and provide key implementation details for employers navigating the City’s expanded leave requirements.
A few important takeaways for HR, payroll, and compliance teams:
- Employers must provide a 32-hour bank of immediately available protected time off upon hire and at the start of each calendar year.
- Existing PTO, sick leave, vacation, or personal days may satisfy some or all of the requirement if they meet PTOL rules.
- Paid protected time off generally must be used before unpaid protected time off, unless the employee requests otherwise.
- Employers must separately track paid protected time off, unpaid protected time off, and paid prenatal leave.
- Policies should be updated to reflect expanded covered reasons, documentation limits, rehire obligations, paid prenatal leave, and post-employment leave-balance access.
For multi-state employers, this is another reminder that leave compliance is becoming increasingly local, detailed, and operational. It’s not enough to have a policy in place; HR, payroll, managers, and systems all need to be aligned.
To read the full alert from Cozen O’Connor, click here.