Labor & Employment Law Daily Wrap Up, EXPERT INSIGHTS—Employer to-do list for Minnesota's new paid leave program, (Nov 6, 2025)

Law Firms Mentioned:Taft Stettinius & Hollister

Organizations Mentioned:Taft Stettinius & Hollister, LLP

By Bethany J. Venegoni of Taft Stettinius & Hollister

As many employers are aware, Minnesota Paid Leave goes into effect on Jan. 1, 2026. Thereafter, Minnesota employees will be eligible to apply for up to 12 weeks of family or medical leave per benefit year through the Minnesota Paid Leave program. Employees who need both family and medical leave in the same benefit year may qualify for up to 20 weeks of Minnesota Paid Leave total. Minnesota employees can apply for Minnesota Paid Leave to: (1) care for their own serious health condition, including care related to pregnancy, childbirth, and recovery; (2) care for and bond with a new child welcomed through birth, adoption, or foster placement; (3) care for a family member with a serious health condition; (4) support a family member called to active duty; and (5) respond to issues related to domestic violence, sexual assault, or stalking of the employee or their family member.

Employer Next Steps

Seasonal Hospitality Employers Apply for an Exemption, if applicable. Seasonal hospitality employers can request a special designation for certain seasonal hospitality employment. Employers that apply and are approved for this exemption will not be required to provide Minnesota Paid Leave or pay the premiums. Approved employers must provide notice to all employees. Employers can now apply for the seasonal hospitality exemption here.
Determine Plan. All Minnesota employers that are currently set up through Minnesota Unemployment Insurance will default to the Minnesota plan if no action is taken. Alternatively, employers can submit an employer equivalent plan or third-party insurer plan for approval. The deadline to opt out of the Minnesota-administered plan and seek approval for an employer equivalent plan or insurer's plan was recently moved to Nov. 15, 2025.
Designate Administrator. Employers must designate a Paid Leave Administrator in their Employer Account by following DEED's step-by-step guide. The Administrator will be the main point of contact between the organization and the state. Employers must also create a Paid Leave Administrator Account at paidleave.mn.gov, which will provide administrators with access to review applications and view Paid Leave determinations.
Determine premium split. Employers can generally deduct up to 50% of the premium through regular payroll deductions. If the employer chooses to share the premium cost with employees, deductions can begin Jan. 1, 2026.
Review policies. Employers will want to review leave policies and determine if any changes are necessary based on Minnesota Paid Leave benefits. DEED launched an Employer Toolkit that provides guidance on benefit calculations, taxability, "top-off" benefit determinations, and answers other frequently asked questions regarding employer policies.
Communicate to employees. By Dec. 1, 2025, employers must provide employees with notice of Minnesota Paid Leave. Employers are required to both hang a Paid Leave poster and inform employees individually.
- Posters must be displayed where employees can easily see them and must be posted in English and any other language that is primary for five or more workers.
- Employees must be notified individually in their primary language, and employees must acknowledge that they have received the information. Employers are encouraged to obtain written or electronic signatures from employees acknowledging receipt and understanding.
- Posters and notices can be downloaded from the For Employers page on the Paid Leave site.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Bethany J. Venegoni

Taft Stettinius & Hollister

41 S. High Street

Suite 1800

Columbus

43215-6106

United States

Tel.: +1 614 334 7102

E-mail: avandyke@taftlaw.com

URL: www.taftlaw.com/

Attorneys: (Taft Stettinius & Hollister).

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