The Cook County Paid Leave Ordinance provides most employees in Cook County the right to earn at least one hour of paid leave for every 40 hours worked – up to a maximum of 40 hours in a 12-month period.

On April 10, 2025, the Cook County Board of Commissioners approved revisions to the Commission on Human Rights Interpretive and Procedural Rules Governing the Cook County Paid Leave Ordinance (“Procedural Rules”). Below is a summary of the revisions made to the Procedural Rules, not inclusive of those applying to county park and school district employees.

Employer Methods for Calculating Paid Leave: Rate of Accrual

Original Rule: Employees accrued one hour of paid leave for every 40 hours worked and while using paid leave hours.

Revised Rule: Employees accrue one hour of paid leave for every 40 hours worked. Employees are no longer entitled to accrue paid leave while using paid leave hours.

Benefit: Compensation and Benefits

Original Rule: An employer that compensated an employee for regular work with additional benefits (paid leave accrual, vacation and/or personal days, seniority, health benefits, etc.), was required to offer those benefits to an employee on paid leave.

Revised Rule: If an employer chooses to offer additional benefits to employees on paid leave, the employer must do so in the same manner and to the same extent as if the employee had performed regular work.

Permissible Employer Usage Policies: Disciplinary Leave

Original Rule: Employers were prohibited from allowing employees to use paid leave when they were suspended or placed on leave for disciplinary reasons.

Revised Rule: Employers cannot require employees to use paid leave when they are suspended or placed on a leave for disciplinary reasons, but employers are permitted to allow employees to use paid leave under these circumstances.

Use: Payment of Paid Leave

Original Rule: Employers were required to compensate employees by the payday for the pay period during which employees were on paid leave.

Revised Rule: Employers are required to compensate employees by the payday for the pay period following the pay period during which employees are on paid leave.

Implications of Revisions for Employers:

Cook County employers should review their paid leave policies to determine what impact, if any, the revised Procedural Rules have on their existing policies and practices. If modifications are required, the Procedural Rules require employers to notify employees of changes to existing policies in writing as soon as practicable, but no longer than five days after making the changes.

Brad and other members of the GCT Employment Law Team are continuing to monitor this area for additional updates and are available to assist you in navigating these new requirements. If you have any questions about the revised Procedural Rules, or any other employment related issues, please contact Brad at bslohsl@gct.law.