2027 Paid Leave Changes in Maryland and Virginia: What Employers Should Do Now
- Laura Dickens
- 2 days ago
- 4 min read
Employers with teams in Maryland and Virginia should use the coming year to review leave policies, payroll processes, employee work locations, and manager guidance. Early planning can help organizations identify gaps and prepare for state-specific requirements before key deadlines take effect.
Paid leave requirements affect more than payroll. For employers with staff in Maryland or Virginia, significant changes are coming in 2027 that may require updates to policies, systems, employee communications, and manager training.
Maryland will begin collecting contributions for its Family and Medical Leave Insurance program, known as FAMLI, in January 2027. Virginia's expanded paid sick leave requirements begin taking effect in July 2027.
For employers in either state, now is the time to understand what applies and begin preparing.
Maryland FAMLI Contributions Begin in January 2027
Maryland's FAMLI program will provide eligible employees with paid, job-protected leave for qualifying family and medical needs beginning in 2028.
Key dates include:
September 1–November 15, 2026: Employers planning to use a private plan in 2027 must submit a Declaration of Intent to avoid State Plan contributions during the seeding period.
January 1, 2027: FAMLI contributions begin.
April 30, 2027: The first Quarterly Wage and Hour Report is due, and State Plan employers must make their first contribution payment.
January 1, 2028: FAMLI benefits become available to eligible employees.
After registration, employers are automatically enrolled in the State Plan unless they pursue an approved private plan. Contribution obligations vary based on employer size.
Employers considering a private plan should pay particular attention to the September 1–November 15, 2026 Declaration of Intent window. Employers that submit an accepted Declaration of Intent can avoid remitting contributions to the State Plan during the 2027 seeding period while they pursue private-plan approval.
Regardless of plan choice, employers should begin thinking about:
How contributions will be handled through payroll
Whether the organization will participate in the State Plan or pursue an approved private plan
How FAMLI will coordinate with existing PTO, parental leave, disability benefits and other leave programs
Which handbook provisions, forms and internal procedures may need to change
How employees will learn about the program
How managers will be prepared to respond to leave requests
Employers will also be required to submit quarterly wage and hour reports beginning in April 2027, including employers that ultimately participate in a private plan.
Virginia's Expanded Paid Sick Leave Requirements Start in 2027
Virginia's paid sick leave law will expand to more employers beginning in 2027.
The requirements phase in based on employer size:
July 1, 2027, for employers with at least 50 employees
January 1, 2028, for employers with at least 25 employees
January 1, 2029, for employers with at least one employee
Covered employees generally accrue at least one hour of paid sick leave for every 30 hours worked and may accrue and use up to 40 hours per year unless the employer allows a higher limit. Accrued leave generally carries over to the following year.
The law also establishes requirements related to permitted uses of leave, employee notice, recordkeeping, and employee protections.
Employers that already provide PTO or another form of paid leave may not need to establish a separate sick leave bank. However, the existing policy must provide sufficient leave and allow employees to use it for the same purposes and under the same conditions required by the law.
That makes a policy review important. A PTO policy may provide enough hours but still need changes to its permitted uses, eligibility requirements, documentation rules, or carryover provisions.
Maryland & Virginia Paid Leave Timeline:
Multi-State Teams Require More Careful Planning
For organizations with employees working in Washington, DC, Maryland, Virginia, or other jurisdictions, leave compliance is rarely as simple as following the rules where the organization is headquartered.
Employee work location can be especially important for hybrid and remote teams.
Maryland FAMLI, for example, uses localization rules to determine whether employment is covered. The analysis focuses on where work is physically performed rather than simply where an employee lives or where the employer is located. Employees who regularly work in more than one state may require additional review.
A multi-state review should examine:
Where each employee regularly performs their work
Which state and local leave requirements apply
Whether the handbook needs state-specific policies or addenda
Whether payroll and HR systems can administer different requirements
How managers and leave approvers should respond to requests
Whether employees are receiving clear and accurate information about their rights
Consistency remains important, but it doesn't necessarily mean applying identical rules everywhere. Policies need to account for the requirements that apply in each location while remaining practical for employees and managers.
What Employers Can Do Now
Organizations don't need to wait until the effective dates to begin preparing. A practical starting point is to:
Confirm employee work locations and organizational headcount. Both can affect which requirements apply and when.
Determine which 2027 requirements apply to your workforce.
Review current sick leave, PTO, family leave, and disability policies.
Talk with payroll and HR system providers about how they plan to support the new requirements.
Identify handbook provisions, forms, and internal procedures that may need to change.
Develop an employee communication plan so employees understand what is changing and when.
Prepare managers before implementation so they know where to direct questions and how to respond to leave requests.
Continue monitoring official state guidance and regulations as implementation approaches.
Start Preparing Before the New Requirements Take Effect
Employers don't need to resolve every detail immediately. But they should know which requirements apply to their workforce, where current policies may fall short, and which payroll or administrative changes will require more lead time.
Starting early gives HR and leadership teams time to coordinate with payroll providers, update policies and communications, and prepare managers without rushing as deadlines approach.
Because implementation guidance may continue to evolve, employers should continue monitoring official state updates and consult qualified legal counsel regarding their specific obligations.
If your nonprofit or association has employees in Maryland, Virginia, or multiple jurisdictions, Vault's HR team can help review current policies, identify areas that may need attention, and develop practical updates that work for your organization and employees. Contact us today to start the conversation.
This article provides general information and is not legal advice.
Resources
Share on Linkedin
