Colorado Supplemental Public Health Emergency Leave Requirement Ends June 9, 2023

What Changed

Colorado's Healthy Families and Workplaces Act (HFWA) included a supplemental provision requiring employers to provide public health emergency leave during declared health emergencies. With the federal public health emergency declarations ending on May 11, 2023, the supplemental leave requirement expires four weeks later — June 9, 2023.

The base HFWA sick leave requirements (48 hours of paid sick leave annually for employers with 16 or more employees) remain in full effect. Only the supplemental emergency overlay is expiring.

Who Is Affected

All Colorado employers who were subject to the supplemental public health emergency leave provisions. This includes employers of all sizes, as the emergency provisions applied broadly during the declared health emergency.

Where It Applies

Colorado statewide.

When It Takes Effect

The supplemental leave requirement expires June 9, 2023 — four weeks after the federal emergency declaration ended on May 11, 2023.

Why It Matters

Employers can discontinue offering supplemental public health emergency leave after June 9, but should not reduce standard paid sick leave benefits under the HFWA. This is a good moment to audit sick leave policies — the base HFWA requirements are permanent, and many employers added emergency-era benefits to handbooks without a clear sunset provision. Policies that reference COVID-specific leave but do not clearly distinguish between emergency and standard leave could create confusion.

The Humareso Take

This is a "cleaning house" moment. If your handbook still references COVID-era supplemental leave, it is time to update. The underlying sick leave law in Colorado is not going anywhere, but the emergency overlay is done. Use this as an opportunity to review and tighten up your leave policies before someone gets confused about what is still required versus what was temporary.

Recommended Action Steps

1. Review your employee handbook for any references to public health emergency leave and update to reflect the June 9, 2023 expiration.

2. Confirm your base HFWA compliance — 48 hours of paid sick leave for employers with 16 or more employees remains in effect.

3. Notify managers that supplemental emergency leave is no longer required, but standard sick leave policies continue unchanged.

4. Audit leave tracking systems to ensure emergency leave codes are deactivated or archived.

5. Contact your Humareso representative if you need help updating your Colorado handbook policies.