Michigan’s sick leave law just got a major update.

If you haven’t adjusted your policies yet, you could be on the hook for compliance risks, administrative headaches, and potential penalties. 

Back in 2023, the Earned Sick Time Act (ESTA) caused plenty of buzz (and confusion). Now in 2025, updated guidance and extended deadlines have clarified what employers need to do, and when. Whether you’re running a small business or managing HR for a multi-site company, these changes matter. 

Here’s everything Michigan employers need to know to stay compliant with the new sick leave rules. 

1. Small Business Deadline Extended 

If your business has 10 or fewer employees and did not employ anyone before February 21, 2022, you’ve just been given a compliance extension. Your new effective date to implement Michigan’s paid sick leave is now October 1, 2025. 

Translation: You have more time to get your policies and tracking systems in order, but you shouldn’t wait until Q4 to act. 

2. Accrual vs. Front-Loading: Know the Rules 

You have two options for providing earned sick time: 

• Accrual: 1 hour earned for every 30 hours worked, with required carryover. 

• Front-loading: Grant the full amount at the start of the benefit year (72 hours for large employers, 40 for small). 

But new rules affect how front-loading applies to part-time employees. 

3. New Requirements for Front-Loading Part-Time Workers 

Employers who choose to front-load sick time for part-time employees must now: 

• Provide a written estimate of expected hours at hire 

• Prorate the front-loaded leave based on that estimate 

• Top up leave mid-year if the employee works more than projected 

This is a significant change, and a compliance trap if you don’t track hours and communicate clearly with your part-time team. 

4. Use Rules: Documentation, Waiting Periods, and Leave Types 

Leave Can Be Used For: 

• Illness/injury (employee or family) 

• Preventive care 

• Domestic violence or sexual assault needs 

• School meetings related to a child’s health or education 

• Public health closures or quarantine orders 

Employers Can: 

• Impose a 120-day waiting period before new hires can use leave (unless you front-load—then it’s available immediately) 

• Require documentation if the absence is three or more consecutive days, but with one important update… 

5. Employers Must Pay for Required Documentation 

If you require documentation for extended leave (e.g., a doctor’s note or court paperwork), you must reimburse any out-of-pocket costs to the employee. 

In short, requiring a note means covering the cost. 

6. Updated Notice Requirements 

Employers must: 

• Provide a written notice of employee ESTA rights by March 23, 2025 

• Post the official LEO sick leave poster 

• Ensure all materials are provided in English, Spanish, and any other language spoken by 10% or more of your workforce 

If you miss these multilingual requirements, your organization is not compliant. 

7. Recordkeeping: More Than Just Tracking Time 

Michigan’s updated guidance clarified that employers must: 

• Maintain records of hours worked and sick time used for at least three years 

• Be prepared to provide LEO access to those records upon request 

If your HRIS or payroll system isn’t tracking this data accurately, now is the time to make changes. 

Action Items for Michigan Employers 

Don’t wait for the October 1 deadline—or worse, a complaint. Use this moment to: 

• Review your current PTO or sick leave policy 

• Decide whether accrual or front-loading is right for your workforce 

• Train managers on notice procedures, retaliation protections, and documentation limits 

• Update your onboarding process to include ESTA notices and multilingual materials 

• Audit your recordkeeping systems for compliance gaps 

Get Ahead of the Deadline 

Michigan’s Earned Sick Time Act is evolving—and if you’re not keeping up, the risk is real. From complex front-loading requirements to expanded language mandates, these changes can catch even seasoned HR teams off guard. 

MP’s HR experts are here to help. We’ll review your policies, optimize your processes, and ensure full compliance before the deadline. 

Connect with an MP HR Advisor today. Let’s ensure your sick leave strategy is proactive, not reactive. 

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