As Leaves Fall, Leave Requests Rise: Are You Compliant With Chicago’s Expanded Rules?
The City of Chicago’s revised final rules interpreting the Chicago Paid Leave and Paid Sick and Safe Leave Ordinance (the “Ordinance”) recently took effect.
As Chicagoans head back to school next month (which undoubtedly means sick days, weather-related closures, and other unexpected schedule changes), now is the time for employers to proactively revisit paid leave policies—if they have not done so already—and seek out guidance from experienced labor and employment legal professionals.
What Happened?
On June 1, 2026, the final rules for administering the Chicago Paid Leave and Paid Sick and Safe Leave Ordinance—which were published in May by the Chicago Commissioner of Business Affairs and Consumer Protection—took effect.
Who is Affected?
The revised final rules affect all employers with employees working within the City of Chicago. This includes Chicago-based employers and employers based outside Chicago’s geographical limits that have remote or telecommuting employees who work in Chicago.
What Changed?
The final rules provide expanded guidance on the following hot-button topics:
What Does Sick Leave Abuse Look Like?
Convenient Timing Around Days Off
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- Repeatedly calling in sick on days right before or after weekends, holidays, vacations, or regularly scheduled days off can suggest that an employee is using sick leave to extend personal time rather than to address a legitimate health need.
Sick Leave as a Substitute for Denied Time Off
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- If an employee requests vacation or personal leave and is turned down, only to then call in “sick” on those very same days, this may indicate the employee is using sick leave as a workaround.
Avoiding Undesirable Shifts or Duties
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- A pattern of taking sick leave specifically on days when an employee is scheduled for less desirable assignments—whether it is an unpopular shift, a particular task, or a specific role—can also raise red flags.
What Should Employers Do Now?
As required by the Ordinance, employers should adopt a reasonable written policy on paid leave and paid sick leave. These policies may be a part of an employer manual, employer handbook, or a separate document.
For additional guidance, consult with Hinshaw’s Labor and Employment team.
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