Missouri voters made their voices heard last November, approving Proposition A—a ballot initiative that includes both a minimum wage increase and a new requirement for employers to provide earned paid sick time (PST). While the first minimum wage increase went into effect on January 1, 2025, the PST requirement is scheduled to begin on May 1, 2025. But like many changes in employment law, this one comes with its share of twists and turns.

Here’s what we know so far—and what Missouri employers should keep an eye on as implementation nears.

First Things First: What’s in Proposition A?

Proposition A establishes a statewide earned PST requirement for most Missouri employers. Here are the key details:

• Accrual: Employees will earn one hour of PST for every 30 hours worked.
• Usage: Employees can use up to 56 hours of PST per year, or 40 hours for employers with fewer than 15 employees. PST can be used in increments of one hour or the smallest increment allowed by the company’s payroll system.
• Carryover: Unused time may carry over, with a cap of 80 hours. However, usage can be limited to 56 hours per year.
• Permitted Uses: Employees can use PST for personal illness, caring for a family member, school closures, or issues related to domestic violence.
• Notice & Recordkeeping: Employers must provide proper notice and keep records related to PST usage, while also ensuring protections against retaliation.

 
Employers with existing paid time off (PTO) policies that meet or exceed these requirements may not need to implement a separate PST policy, as long as the existing policy covers similar uses. Existing policies should be carefully reviewed to help ensure compliance with all aspects of the law.

A Key Date: Notice Was Due April 15

Although the PST requirement doesn’t go into effect until May 1, 2025, the law included a notice provision that required employers to provide written notice to employees by April 15, 2025. The notice should summarize key provisions like accrual, usage, and anti-retaliation protections and be printed on a single 8.5″ x 11″ sheet in 14-point font. The MO DOL has provided a notice that can be found here.

While no formal guidance has been issued, it’s likely that a printed notice is the safest approach. Electronic notices may not fully satisfy the requirement, so employers should be cautious and provide the printed notice where possible.

Legal Challenge Puts the Law’s Future in Question

There’s a bit of uncertainty on the horizon, as the Missouri Supreme Court is currently reviewing Proposition A following a legal challenge. The lawsuit claims the law improperly combined two unrelated issues—minimum wage and paid sick time—which could violate the state constitution. Oral arguments were held in March, and a ruling is expected later this year.

If the court rules that the law is unconstitutional, all or part of it could be overturned, which could significantly change how employers need to prepare.

Legislative Activity Could Bring More Changes

In addition to the court case, state lawmakers are also weighing in. House Bill 567 initially proposed delaying the PST requirement until January 2026. However, the bill was later amended to remove the PST portion entirely. The bill has passed the House and is now under review by the Senate.

Because the bill lacks an emergency clause, if it passes, it wouldn’t go into effect until late August 2025. For now, the law as it stands requires compliance starting May 1, 2025—at least through the summer. Employers should stay updated on this legislation, as changes could come quickly.

What Employers Might Consider Doing Now

Given the current uncertainty, here are a few steps Missouri employers may want to take to prepare:

• Review Notice Requirements: Double-check that the required employee notice was provided by April 15.
• Evaluate PTO Policies: Assess your current PTO or sick leave policies to determine if they align with the new law’s requirements.
• Prepare HR Teams: Make sure supervisors and HR teams are informed about the potential changes to help smooth implementation.
• Stay Updated: Keep an eye on updates from the courts and legislature to stay ahead of any new developments.

Looking Ahead

As with many policy changes, things are still evolving. While Proposition A remains in place for now, the outcome of the court case and ongoing legislative discussions could influence what the final rules look like. The key is to stay informed and take reasonable steps to prepare for the changes, whatever happens.

We’ll continue monitoring the situation and will share updates as new information becomes available. Have questions? Reach out to your KPM advisor or contact us through our website.