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Does Your Federal Contractor Paid Sick Leave Policy Comply with Prop. 206?

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Companies that entered into qualifying federal contracts since January 1, 2017 are required to have a sick leave policy, or an equivalent paid time off policy, that complies with federal Executive Order 13706. That Executive Order requires, among other things, that employers provide up to 56 hours of paid sick time each year. Arizona’s Fair Wages and Health Families Act (“Prop. 206”), due to take effect on July 1, 2017, requires, among other things, that employers provide up to 40 hours of paid sick time each year. Both of these paid sick leave laws have unique requirements.

Importantly, the mere fact that an existing policy provides for 56 or more hours of paid sick time does not mean that it necessarily complies with Executive Order 13706. Similarly, just because an existing PTO policy provides at least 40 hours of paid sick time does not mean that it complies with Prop. 206.

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