Cook County, IL: Updates to Paid Leave Rules

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Employers with Employees in Cook County, IL

EFFECTIVE

April 10, 2025

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Quick Look

  • Cook County, IL has revised its paid leave ordinance rules, clarifying accrual based on hours worked, pay dates for used leave, additional benefits during leave, and use of leave during disciplinary suspensions.

Discussion:

On April 10, 2025, the Cook County Board of Commissioners approved further revisions to the Commission on Human Rights’ Interpretive and Procedural Rules implementing the County’s paid leave ordinance. Key aspects of the revisions are summarized below.

 

No Accrual of Paid Leave When Using Paid Leave. The original rules had required employers to allow employees to accrue paid sick leave while they were out of work using statutory paid leave; however, the revised rules now confirm that paid leave accrues based on actual “hours worked.”

 

Clarification of Pay Date When Paid Leave Used. The Ordinance’s initial rules required payment for used paid leave by the payday for the pay period during which the employee used such leave. The revised rules amend this requirement, now requiring payment by the payday for the pay period after the pay period during which the employee used leave.

 

Additional Benefits While on Paid Leave. The revised rules indicate that, if an employer elects to provide additional benefits when employees use statutory paid leave (e.g., paid leave accrual, seniority or health benefits), they must do so in the same manner and to the same extent as if the employee had performed regular work.

 

Use of Paid Leave on Suspension or Disciplinary Leave. The revised rules clarify that, while an employer cannot require an employee to use accrued statutory paid leave while placed on suspension or other disciplinary leave, an employer may choose to allow employees to use it under these circumstances. Previously, employers were prohibited from allowing employees to do so.

 

Action Items

  1. Review paid leave policies and practices and update accordingly.
  2. Have appropriate personnel trained on paid leave requirements.
  3. Provide appropriate notification to employees if paid leave policy is updated or modified.

Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2025 ManagEase