Paid Sick Leave Puzzle: Navigating Pittsburgh’s Updates and Allegheny County’s Consistency

Margaret M. Grimm, Esq., (412) 594-5510, mgrimm@tuckerlaw.com

Sick leave in the Steel City received a significant boost as of January 1, 2026. To assist with interpretation and implementation of the new ordinance, the City of Pittsburgh Mayor’s Office provides guidelines to clarify the application and administration of the ordinance. The guidelines received some noticeable changes that employers should be aware of as they navigate ordinance’s mandate for increased sick time and accrual rates. While Pittsburgh’s sick leave rules are evolving, Allegheny County’s remain the same, creating potential challenges for employers who must comply with both sets of regulations.

Recap: What Changed on January 1, 2026?

Effective January 1, 2026, the Pittsburgh Paid Sick Days Act increased the amount of sick time employers of all sizes must provide to their employees annually. The new ordinance implemented faster accrual rates and increased hour requirements for employees working within the geographic boundaries of the City of Pittsburgh.

Key Updates to the Guidelines for Interpretation, Implementation, and Enforcement

On December 9, 2025, the Mayor’s Office unveiled new guidelines for the Pittsburgh Paid Sick Days Act, outlining how the Office of Equal Protection will enforce the updated ordinance. These revised guidelines, which also went into effect on January 1, 2026, introduce several changes employers should take note of, including:

1. Notification and maintenance of accrued sick time.

The revised guidelines now require employers to notify employees of the amount accrued sick time. Section 10(a) of the revised guidelines states that employers “shall choose and maintain a reasonable system for providing notification of accrued sick time, including listing updated amounts of sick time on pay stubs (e.g., regular payroll statements) or in an online system where employees can regularly access information.

This mandatory record keeping of accrued sick time is the most noticeable departure from the former guidelines, which only recommended employers choose a reasonable system for providing notification of accrued sick time.

2. Equivalent or excess PTO policies.

Employers that provide paid time off (PTO) that meet or exceed the requirements under the Act are considered complaint with the Act’s sick leave requirements and are not required to offer additional sick time. However, the revised guidelines make clear that any PTO policy that requires employees to provide advance written notice, finding their own replacement, or is subject to employer approval or refusal is not compliant with the Act’s minimum requirements.

3. Record retention.

Section 626.07(a) requires employers to retain records documenting hours worked by employees and sick time taken for a period of two (2) years. The revised guidelines add that employers must retain records of their Paid Sick Leave policy for two (2) years, in addition to retaining records of hours worked and sick time taken.

The revised guidelines further advise that if an employer fails to maintain adequate records or does not allow the Office of Equal Protection to review the records, the Office of Equal Protection will assume the employer violated the Act.

No Update for Allegheny County

While the Pittsburgh Paid Sick Days Act and its guidelines have undergone their fair share of revisions, the Allegheny Paid Sick Days Act has yet to update, making compliance for employers challenging.

Prior to the amendments, the Pittsburgh Paid Sick Days Act and the Allegheny Paid Sick Days Act almost mirrored each other, requiring similar hours and accrual rates. The only noticeable difference being that the Pittsburgh Paid Sick Days Act applies to all employers, regardless of size, while the Allegheny Paid Sick Days Act requires a minimum of 26 employees to apply.

Now, the Pittsburgh Paid Sick Days Act requires faster accrual rates (1 hour of sick time per 30 hours worked rather than 35 hours worked) and increased sick time (up to 48 or 72 hours of sick time per year, depending on the number  of employees, rather than 40 hours).

Allegheny County shows no signs of matching Pittsburgh’s increased sick time. These significant differences in requirements present a unique challenge to employers with employees who work within the geographic boundaries of the City of Pittsburgh and Allegheny County.

Employers with employees covered by the Pittsburgh Paid Sick Days Act and the Allegheny County Paid Sick Days Act should review their policies to ensure they are in compliance with both. If you need assistance updating your policies and employee handbook, or need guidance navigating the paid sick leave puzzle employers may find themselves in, contact Maggie Grimm at (412) 594-5510 or mgrimm@tuckerlaw.com.