What Happened?

As we covered in our previous update, Pittsburgh had amended its Paid Sick Days Act to expand employee benefits and clarify responsibilities for employers with employees working in the City of Pittsburgh, Pennsylvania. In an effort to align guidelines with the amendments, the Office of Equal Protection issued revised guidelines for administering the Pittsburgh Paid Sick Days Act (PSDA).

These revisions became effective January 1, 2026, and focus on accrual accuracy, transparency, recordkeeping, and enforcement.

Overview

• Effective date: The revised PSDA Guidelines took effect January 1, 2026.

• Who is covered (threshold): The PSDA applies to employees who work at least 30 hours within the geographic boundaries of the city of Pittsburgh in a calendar year. Coverage is based on where the work is performed, not where the employer is located and only the hours worked within the city limits count toward the threshold.

• Accrual rate increases: Employees accrue at least 1 hour of paid sick time for every 30 hours worked in the City.

• Annual caps increase: City notice materials reflect caps of up to 72 hours/year (15+ employees) and up to 48 hours/year (smaller employers). Employee-count threshold is based on the employer’s total number of employees overall and not just those employees working in Pittsburgh.

• Mandatory balance notice: Employers must provide a reasonable way for employees to see accrued sick time (e.g., on pay stubs or via an online system employees can access).

• Using Paid Time Off (PTO)/Collective Bargaining Agreement (CBA) policies: Existing PTO/CBA leave counts only if it can be used for the same purposes and under the same conditions as PSDA sick time; policies requiring advance/written notice, finding a replacement, or employer approval/refusal do not qualify.

• Frontloading tightened: If any portion is frontloaded, it must be based on a reasonable calculation, so accrual meets or exceeds the minimum and never falls below what they would have earned via accrual.

• Recordkeeping expanded: Keep records of the paid sick leave policy, hours worked, and sick time taken for 2 years, and allow City review with notice.
  • Frontloading does not eliminate tracking obligations.

• Carryover: Employees may carry over unused accrued sick time to the next year unless the employer frontloads the full required annual amount at the start of the year, 72 hours for employers with 15+ employees or 48 hours for employers with fewer than 15 employees. These updated thresholds replace the prior 40/24 caps

• Enforcement clarified: Failure to respond to Office inquiries can result in a presumption of violation and may be treated as a waiver; the City may also require posting/notice of an ongoing investigation.

Why this matters: These revisions increase day-to-day compliance expectations (policy design, leave tracking, and balance visibility) and strengthen enforcement tools that can increase exposure if issues arise.

Key Risks for Employers

• Not providing employees their accrued sick time balance via pay stub or an accessible online method.

• Relying on a PTO/CBA policy that adds conditions the PSDA does not allow, such as approval requirements, replacement requirements, or strict written/advance notice rules.

• Frontloading incorrectly, especially where heavy overtime work could cause accrual to fall behind the required rate during the year.

• Incomplete recordkeeping (policy + hours worked + sick time taken for 2 years), which can weaken defenses in a City review.

• Missing response deadlines to the Office of Equal Protection, increasing risk of presumed violation/waiver.

Bottom Line: Employers must update their policies and ensure their systems are correctly configured to meet the 2026 PSDA requirements, including higher caps, faster accrual, balance visibility, and updated carryover rules, because the City has strengthened oversight and enforcement.

Source References

• City of Pittsburgh – Ordinance and Guidelines
• City of Pittsburgh – Paid Sick Leave Act (Rev. 01/13/2026)
• City of Pittsburgh – Paid Sick Leave Act Resources
• City of Pittsburgh – Guidelines v. 4.1 for Administering Pittsburgh City Code Chapter 626, “Paid Sick Days Act,” (Rev. 12/09/25)
• Pittsburg, Pennsylvania, Updates Paid Sick Days Act to Expand Employee Benefits (VensureHR)

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