There is no federal law that requires private employers to provide paid sick leave. The only federal floor is the unpaid Family and Medical Leave Act (FMLA, 29 U.S.C. § 2601), and it applies only to employers with 50 or more employees within a 75-mile radius. So the question every multi-state employer actually asks is not "is it required?" but "how many employees trigger paid sick leave in each state where I operate?"
The answer is a patchwork. As of 2026, 21 states plus dozens of cities mandate some form of paid sick leave, and the headcount trigger ranges from a single employee to 50. Below is the verified threshold map, drawn directly from each state's labor code.
The 2026 State Threshold Map
| State | Employer threshold | Accrual rate | Annual cap |
|---|---|---|---|
| Alaska | 1 employee | 1 hr / 30 hrs | 40 hrs (<15 emp); 56 hrs (15+) |
| Arizona | 1 employee | 1 hr / 30 hrs | 24 hrs (<15); 40 hrs (15+) |
| California | 1 employee | 1 hr / 30 hrs | 80 hrs accrual; 40 hrs use |
| Colorado | 1 employee | 1 hr / 30 hrs | 48 hrs |
| Connecticut | 11+ (2026); 1+ (Jan 1, 2027) | 1 hr / 30 hrs | 40 hrs |
| Washington DC | 1 employee | 1:87 (1–24); 1:43 (25–99); 1:37 (100+) | 3 / 5 / 7 days |
| Illinois | 1 employee | 1 hr / 40 hrs | 40 hrs |
| Maine | 11+ (>10 in usual course >120 days/yr) | 1 hr / 40 hrs | 40 hrs (+40 carryover) |
| Maryland | 15+ (paid); smaller unpaid | 1 hr / 30 hrs | 40 hrs |
| Massachusetts | 11+ (paid); smaller unpaid | 1 hr / 30 hrs | 40 hrs |
| Michigan | 11+ (10 or fewer: 40 hrs, may be unpaid) | 1 hr / 30 hrs | 72 hrs (11+); 40 hrs (≤10) |
| Minnesota | 1 employee | 1 hr / 30 hrs | 48 hrs (80 if no other PTO) |
| Nebraska | 11+ (10 or fewer exempt) | 1 hr / 30 hrs | 40 hrs (80 if no PTO) |
| Nevada | 50+ employees | ~0.01923 hr / hr worked | 40 hrs |
| New Jersey | 1 employee | 1 hr / 30 hrs | 40 hrs |
| New Mexico | 1 employee | 1 hr / 30 hrs | 64 hrs |
| New York | 5+ or $1M net income | 1 hr / 30 hrs | 40 hrs (5–99); 56 hrs (100+) |
| Oregon | 10+ (6+ if Portland location) | 1 hr / 30 hrs | 40 hrs |
| Rhode Island | 18+ employees | 1 hr / 35 hrs | 40 hrs |
| Vermont | 1 employee | 1 hr / 52 hrs | 40 hrs |
| Washington | 1 employee | 1 hr / 40 hrs | No cap; 40 hr carryover |
Delaware has no statewide sick-leave mandate but runs a Paid Family and Medical Leave program (benefits from Jan 1, 2026). Missouri's Proposition A mandate took effect May 1, 2025 but was repealed Aug 28, 2025, so Missouri is again non-mandated.
What the Threshold Map Tells Employers
- Eleven states reach down to "1 employee." Alaska, Arizona, California, Colorado, DC, Illinois, Minnesota, New Jersey, New Mexico, Vermont, and Washington cover even sole-proprietor-scale businesses. If you have a single worker in any of these, you must accrue paid sick time from day one.
- Five states draw the line at 11+. Connecticut (through 2026), Maine, Massachusetts, Michigan, and Nebraska exempt the smallest employers — but Massachusetts and Maryland carve out unpaid job-protected leave for the smaller group, so "exempt" is not the same as "nothing."
- The high bars are rare. Only Rhode Island (18+) and Nevada (50+) sit well above 11. Nevada's 50-employee line mirrors the federal FMLA threshold, so a Nevada business at 50 is suddenly inside both state and federal leave regimes.
Three Triggers That Surprise Employers
1. The 120-day rule (Maine)
Maine counts an employer as "11+" only if it regularly employs more than 10 people in the usual course of business for more than 120 days per year. A seasonal operator under 120 days stays outside the mandate even with dozens of summer hires.
2. Multi-state headcount is not aggregated for the state threshold
Most state thresholds look at employees in that state, not nationwide. A 200-person company with 3 people in California is a "1-employee" covered employer in California. (The federal FMLA, by contrast, counts all employees in the 75-mile radius.)
3. Local ordinances can be stricter than the state
Even in a "1-employee" state, cities like Seattle, San Francisco, and New York City layer on their own accrual and front-loading rules. The state threshold is the floor, not the ceiling.
How to Use the Compliance Checker
Rather than hand-mapping headcount against 21 statutes, open the paid-leave compliance checker, enter the states where you have workers and your headcount in each, and get a per-state yes/no with the governing threshold. Then confirm against the full 50-state paid-leave guide.
Sources: dayfig.com 50-state paid-leave dataset (state labor codes, retrieved 2026-09-21). This is informational, not legal advice — confirm thresholds with each state's labor department before setting policy.