This page turns the Cook County Paid Leave Ordinance into a routine we call the Forty-Hour Ledger Pass. It applies to work in Cook County; Chicago and workplaces outside the county follow other laws. An employer can run it yearly and when a new site opens. See the rules and numbers for figures.
The Forty-Hour Ledger Pass
- Sort your sites. Note whether each work site is in Chicago, a Cook suburb that follows the County, a suburb that chose the state law, or outside Cook County. Ask the village hall when unsure.
- Pick a method. Accrue 1 hour per 40 hours worked, or front-load 40 hours (pro rata for part-timers).
- Write the use rules. Leave opens after 90 days, for any reason. Blocks may be limited to 2 hours; any notice rule (up to 7 days when foreseeable) goes in writing.
- Post and hand out. Post the County notice at each Cook County site, send it to remote staff, and give each employee the written policy at hire and yearly.
- Build the ledger. Record hours worked, leave earned and used, balances and denied requests, and keep them 3 years.
- Settle carryover and payout. Keep any carryover cap at 40 hours or more, and plan payout for leave held in a PTO or vacation bank.
- Check pay. Use the regular hourly rate; tipped and commission workers get at least the full minimum wage where they work (the County minimum wage in towns that follow it).
- Recheck in January and July. Look for new Rules or FAQs on the County page and for local changes where you have sites.
Common mistakes
- Requiring a reason, a doctor's note or a replacement worker.
- Counting paid leave as a point under a no-fault attendance policy.
- Missing the County poster, the notice at hire or the yearly written policy.
- Giving fewer hours than earned, or paying tipped staff the tipped cash wage during leave.
- Not paying out a PTO or vacation bank at separation.
- Assuming an old Earned Sick Leave Ordinance opt-out still protects a suburb.
When to talk to an attorney
A CPA cannot answer these legal questions:
- Whether a suburb's opt-out is valid, or which law governs sites in Chicago, an opted-out suburb and another county.
- A Commission complaint, subpoena or audit, or a suit seeking three times the unpaid leave.
- A union-contract waiver, or "unlimited PTO," forfeiture and payout policies under the Illinois wage payment law.
- Whether workers are employees or contractors, since penalties can double.
Frequently asked questions
Does the Cook County paid leave ordinance apply to small businesses?
Yes. It covers any employer with at least one employee working in Cook County, and neither the ordinance nor the state act sets a small-business exemption.
Is Cook County paid leave the same as sick leave?
No. Since December 31, 2023 the ordinance covers leave for any reason, with no reason or note needed. It replaced the earlier Earned Sick Leave Ordinance, whose old rules no longer apply.
Must unused leave be paid out when an employee leaves?
Only if the leave was credited to a paid time off or vacation bank. The County Rules then call for payment at the regular rate at separation if possible, and no later than the next regular payday.
Which law applies if my business is in DuPage, Kane, Will or Kendall County?
The Illinois Paid Leave for All Workers Act applies there, unless a local paid leave ordinance already covered the employer on January 1, 2024. It uses the same 1 hour per 40 hours worked and a 40-hour yearly minimum. Staff who do at least half of their paid work in Cook County may fall under the County ordinance.
A CPA can help with the payroll, tax and accounting side, including payroll services, and works alongside your attorney on the legal questions.
Official sources
- Cook County: Paid Leave Ordinance and Regulations
- Cook County: Paid Leave Ordinance FAQs, December 2024
- Cook County Commission on Human Rights: Paid Leave Ordinance Rules, April 2025
- Illinois Department of Labor: Paid Leave for All Workers Act FAQ
This page is a plain-language summary. The official source controls if there is any difference.