Cook County Replaces Sick Leave Ordinance with Broader Paid Leave Requirement

What Changed

The Cook County Board of Commissioners passed the Cook County Paid Leave Ordinance, replacing the existing Cook County Earned Sick Leave Ordinance. The key change: employees now earn leave that can be used for any reason, not just illness. Under the new ordinance:

Employees earn at least one hour of paid leave for every 40 hours worked
Paid leave can be used for any reason of the employee's choosing
Employees may begin using paid leave 90 days after the start of employment or 90 days after December 31, 2023, whichever is later

This change aligns Cook County's leave requirements with the State of Illinois Paid Leave for All Workers Act, which also takes effect on January 1, 2024.

Who Is Affected

All employers with employees working in Cook County, Illinois. The ordinance does not distinguish between full-time, part-time, or seasonal employees — all are covered. Park and school districts have a delayed effective date of January 1, 2025.

Where It Applies

Cook County, Illinois (unincorporated Cook County and municipalities that have not opted out of the ordinance). Employers should note that this ordinance operates alongside the Chicago Paid Leave Ordinance and the Illinois state Paid Leave for All Workers Act — employees in Chicago may be subject to the Chicago ordinance rather than the Cook County version.

When It Takes Effect

December 31, 2023. Enforcement by the Cook County Commission on Human Rights began February 1, 2024.

Why It Matters

The shift from sick-leave-only to general paid leave is significant. Previously, employers could require employees to justify their leave under qualifying conditions. Now, employees can use their accrued leave for any purpose without providing a reason. This simplifies administration in some ways but also requires updated policies and employee communications.

Employers who previously complied with the Earned Sick Leave Ordinance must update their policies to reflect the broader scope of the new ordinance.

The Humareso Take

Cook County followed the state's lead here, and the result is a simpler but broader leave requirement. The good news: you no longer need to police whether someone's leave is for a "qualifying" reason. The potential headache: if you have employees in Chicago, Cook County, and elsewhere in Illinois, you are now juggling three overlapping paid leave regimes. We strongly recommend mapping out exactly which law applies to each of your work locations and building a leave policy that meets the most generous standard.

Recommended Action Steps

Update your leave policy to replace references to the Earned Sick Leave Ordinance with the new Paid Leave Ordinance, reflecting that leave may be used for any reason.
Determine which employees are covered by the Cook County ordinance versus the Chicago ordinance or state law, based on where they perform work.
Communicate the change to employees — they should know that their leave is no longer restricted to sick-leave purposes.
Update leave tracking systems to reflect the new accrual rate (one hour per 40 hours worked) and the 90-day waiting period for new hires.
Contact your Humareso representative for help reconciling Cook County, Chicago, and Illinois state paid leave requirements for your workforce.