Get Well Soon, But Take Your (Sick) Time: Pittsburgh Increases Paid Sick Time Accrual

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Peter Nakonechni

November 19, 2025

On June 10, 2025, the Pittsburgh City Council passed an ordinance (No. 2025-1736) amending its Paid Sick Days Act (the “Act”) to increase the rate at which employees can accumulate paid sick time and to increase the maximum total amount of paid sick time hours an employee can accumulate.

The amendments, which are effective January 1, 2026, allow employees to accrue paid sick time faster and have substantially more hours available each year. All full-time and part-time employees who work more than 35 hours per week per year can now accrue one hour of sick time for every 30 hours worked,[1] with annual caps of up to 72 hours for employers with 15 or more employees and up to 48 hours for employers with fewer than 15 employees.

Prior rules and administrative requirements regarding carryover, frontloading, use, and timing for accrual/use still apply. Specifically, accrued sick time typically carries over to the following year unless an employer “frontloads” the required annual sick time (i.e., employer provides the 48 or 72 hours of paid sick time at the beginning of the calendar year). An employee can carry over unused sick time, but only up to the 48- or 72-hour maximums.[2]  Further, new employees may use accrued sick time starting 90 days after their hire date.

Benefits to Employees
The Act applies to employees working 35 or more hours per week per year within the City of Pittsburgh. An employee’s ability to accrue paid sick time at a quicker rate provides them with faster access to paid time off for their own healthcare needs and to care for relatives who are ill or injured. The new annual caps significantly increase the guaranteed amount of paid sick time that can be accrued compared to the prior law (48/72 hours vs. 24/40 hours), which in turn greatly improves an employee’s financial security when they or their family members fall ill. Keeping the carryover protections in place guarantees that employees will not lose unused sick time at year-end (unless the employer frontloads the requirement amount).

The Act also allows employers to provide faster accrual rates and designate a higher annual cap at the employers’ discretion.

Impact on Employers
The Act’s increases in accrual rate and annual caps may result in employers having increased paid leave payouts throughout the year, which can result in higher direct payroll costs and significantly affect employers operating on thin margins; while employers utilizing smaller staffs may have coverage issues when multiple employees take paid sick time contemporaneously.

The Act also contains several administrative requirements for employers:

  • Employers must provide written notice to their employees that they are entitled to paid sick time, the amount of paid sick time, the restrictions on the use of paid sick time, that retaliation is prohibited against employees who request or use paid sick time, and that employees have the right to file a complaint with the Office of the City Controller (or other designated entity) if required sick time is denied or the employee is retaliated against for requesting or taking sick time.
  • Employers are required to track hours worked within Pittsburgh city limits and hours accrued, used, and carried over. Employers must ensure that they maintain updated timekeeping records, human resources records, and payroll configurations, and accurately track work hours for employees who split their time working within and outside of Pittsburgh.
  • Employers must update their written policies, employee notices, and handbook language to reflect the changes in the Act.
  • Employers must evaluate cashflow and administrative costs to decide whether to frontload their employees’ paid sick time. While front-loading can simplify administrative procedures, it can negatively impact the early-year cash on hand because employers must immediately cover the full balance of paid sick time.
  • Employers that offer paid time off (PTO) plans must ensure that these plans meet or exceed the Act’s requirements and comply with the Act’s carryover and use rules.

Penalties for Violating the Act
Any employer who willfully violates the requirements of the Act is subject to a maximum penalty of $100.00 for each separate offense. However, no fines will be imposed against any employer during the first year that the Act is effective (January 1, 2026 through January 1, 2027).

If an employee’s complaint results in a finding that an employer violated the Act, an employee can receive full restitution for all lost wages, benefits, and reinstatement. If an employee violates the Act, an employer may be permitted to take disciplinary action against the employee pursuant to the employer’s policies.

 

This article is designed to provide one perspective regarding recent legal developments, and is not intended to serve as legal advice.  Always consult an attorney with specific legal issues.

 

[1] Previously, employees accrued one hour of sick time for every 35 hours worked.

[2] For example, if an employee of an employer of 15 or more employees carries over 20 hours of sick time from 2025 into 2026, the employee can accrue only 52 hours of paid sick time in 2026.

 
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