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11.10.25
Your PFML Compliance Checklist
By Cale Dunwoody, Vice President of Public Policy, FMWF Chamber
Get PFML compliance right before January 2026. Follow this checklist to prepare your business for Minnesota’s Paid Leave.
The countdown is on: Minnesota’s Paid Family and Medical Leave (PFML) program goes live Jan 1, 2026. Employers need to take specific steps before then to stay compliant and prepare their workplaces.
If you have employees working in Minnesota, now’s the time to prepare. Here’s a simple checklist to make sure your organization is prepared.
Set Up Your Employer and Administrator Accounts
Employers must register for accounts in two separate online systems.
- Register for an Employer Account, if you need one. All employers must be connected to Minnesota’s Unemployment Insurance System (if you don’t already have one). With this account, you will: Submit quarterly wage detail reports, Pay Paid Leave premiums and designate a Paid Leave Administrator.
- Designate your Paid Leave Administrator in your Employer Account. Log in to your Employer Account and designate a Paid Leave Administrator. The Paid Leave Administrator will be your main point of contact with Minnesota Paid Leave. You can designate one person, or several.
- For help, refer to the step-by-step guide.
- Establish a Paid Leave Administrator Account. Once you have designated a Paid Leave Administrator, that individual will receive a confirmation email. They are now ready to set up their Paid Leave Administrator Account through the Minnesota Paid Leave System. With this account, you will: Review leave applications, view Paid Leave determinations, access tax filing information, apply for Small Employer Assistance Grants and request an Equivalent Plan Substitution.
- Visit paidleave.mn.gov: Create Your Paid Leave Administrator Account.
- Enter your email address and create a password. Be sure to use the same email address as the one where you received your confirmation message.
- Select Create account.
Key Resources
Decide Between the State Plan or an Equivalent Private Plan
Employers can choose to meet their responsibilities under Minnesota Paid Leave by providing employees with an equivalent private plan that meets or exceeds the coverage offered by the State.
Employers have two options for equivalent private plans:
- A private insurance carrier plan: a type of equivalent plan sold by private insurers. The plan must be approved by the Department of Commerce and meet or exceed all statutory requirements.
- A self-insured plan: a type of equivalent plan where an employer manages employees’ paid leave requests and payments themselves, rather than through an insurance carrier or the State. Self-insured plans must be backed up by a surety bond to ensure they can make payments to employees who take leave.
An equivalent plan must offer the same or better coverage than Minnesota Paid Leave, and it must not cost your workers more than they would be required to contribute under the state plan. It must also provide job protections equal to those in the state plan.
Employers must apply for an Equivalent Plan Substitution through the Minnesota Department of Employment and Economic Development (DEED). Employers approved for an equivalent plan will not pay PFML payroll taxes to the State but must still meet reporting and compliance obligations.
For your equivalent plan to take effect starting Jan. 1, 2026, your request must be received by Paid Leave by Nov. 15, 2025. If you submit your request after Nov. 15, the earliest your equivalent plan could be start is April 1, 2026 (the start of the next quarter).
Key Resources
Notify Your Employees about PFML
Notify Your Employees about PFML: Employers must inform every worker about the new Paid Family and Medical Leave benefits and rights by Dec. 1, 2025.
- Workforce Poster: Must be displayed prominently at each worksite, in English and any language spoken by five or more employees or contractors.
- Individual Notice: Employers must notify each employee directly about Paid Family and Medical Leave in their primary language within 30 days of hire or by Dec. 1, 2025 (30 days before payroll deductions begin). This can be done by signing a form, acknowledging receipt electronically (for example, in your payroll system) or in another way you decide.
- Acknowledgment: Keep records of employee acknowledgment or proof that notice was provided. If an employee claims they weren’t notified, the burden of proof is on the employer.
Key Resources
Update Your Policies and Procedures
Your internal policies and payroll systems must align with PFML compliance requirements before the program goes live.
- Premium Split: Confirm premium deduction splits between employer and employee (an employer must cover at least 50% of the premium cost), which is set to begin Jan. 1, 2026.
- Notification and Documentation Process: Employees must tell you before applying for Paid Leave. Update your leave request and approval process to align with PFML requirements.
- Leave Benefit Coordination: Paid Leave only replaces part of an employee’s wages. As an employer, you decide whether to allow certain other benefits – including vacation and sick time – to “top off” payments from the program. If you allow it, employees can choose to use these supplemental payments to make up the difference between Paid Leave and their regular wages while on leave. If you decide not to allow supplemental payments, employees who want to receive their full, usual wage while on leave need to use their vacation, sick time or other paid time off instead of Paid Leave.
- Benefit Continuation: Employees keep their benefits and maintain coverage. This means that, if an employer provides benefits like health insurance, life insurance or retirement benefit accrual, employees have the right to keep their coverage while on leave. Employers must continue to pay health insurance premiums, and employees will continue to pay your portion as if you were working.
- Leave Increments Policy: Employees can take leave in small blocks of time rather than all at once. This is called intermittent leave. You decide the shortest block of time an employee can use, from one minute up to one day. You can also decide how much leave time can be taken as intermittent leave. Employees can take up to 480 hours of leave intermittently each year if they qualify (the equivalent of 12 weeks at 40 hours per week). If someone qualifies to take up to the maximum 20 weeks of leave in a year, you can decide if that additional time can also be taken intermittently, or if it must be taken in one continuous block.
Key Resources
PFML Compliance Deadlines to Know
- Nov. 15, 2025: Equivalent Plan Substitution Requests due for Q1 of 2026
- Dec. 1, 2025: Employee notifications due
- Jan. 1, 2026: Payroll deductions begin; PFML benefits available to employees
- April 30, 2026: First quarterly premiums due
Learn More About PFML Before You Get Started
If you’re just beginning your PFML compliance planning, make sure you’re caught up on the first two parts of our Minnesota Paid Family and Medical Leave blog series:
- Minnesota Paid Family and Medical Leave: What Employers Need to Know – Get an overview of who’s covered, the types of leave included and how the program will affect Minnesota businesses.
- Minnesota Paid Family and Medical Leave: Premiums, Taxes and Employer Costs – Learn how payroll deductions work, how costs are shared between employers and employees and what to expect when premiums begin in 2026.
These two resources lay the groundwork for understanding the program before completing your PFML compliance checklist and preparing your organization for implementation.
Additional Resource for Employers
For a detailed, printable overview of key PFML steps and deadlines, download the Minnesota Chamber of Commerce PFML Business Checklist (PDF).
Disclaimer: Please consult an HR professional or employment attorney to ensure full PFML compliance for your business. Information in this article was sourced from the Minnesota Department of Employment and Economic Development (DEED) to ensure accuracy and clarity for employers preparing for Minnesota Paid Family and Medical Leave compliance.
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