LawFlash

Washington State Year-End Legislative Developments Employers Need to Know

August 12, 2025

Washington state recently enacted a slew of laws that will impact employers across the state. Most of the new laws expand protections for employees, but some offer relief to employers as they adjust to new requirements. Washington employers should be aware of changes to leave requirements, new layoff restrictions, new workplace accommodation requirements, expansion of employee access to personnel files, updates to meal and rest break requirements for hospitals, and updated requirements related to job postings and applicant criminal records.

CHANGES TO WASHINGTON PAID FAMILY AND MEDICAL LEAVE

Effective January 1, 2026, HB 1213 amends Washington’s Paid Family and Medical Leave (WA PFML) law to expand job protection and close a loophole that currently allows employees to stack leave.

Highlights from the amended law that employers should know:

Shortens Service Requirement for Job-Protected Leave

In order to take job-protected leave, employees now only need to be employed for 180 days prior to the start of leave. Previously, employees were required to perform 1,250 hours of work within the 12 months prior to the start of leave in order to take protected leave.

Closes Leave Stacking Loophole

Employers may count leave taken under the Family and Medical Leave Act (FMLA)  toward an employee’s WA PFML benefit even when employees do not apply for it. However, employers must give written notice to employees within five business days of the earlier of either an employee’s request for leave or use of leave. The bill includes a phased approach to implementation of this change based on employer size.

Employees May Forfeit Right to Reinstatement

Employees now risk forfeiting their right to reinstatement unless they affirmatively exercise the right upon the earlier of the first scheduled workday at the end of WA PFML or the first scheduled workday following unpaid FMLA leave where the employee was eligible for WA PFML but did not apply for it.

Employers Must Notify Employees Regarding Potential Forfeiture of Right to Reinstatement

For continuous periods of leave of more than two typical workweeks or any combined intermittent leave of more than 14 combined workdays, employers must give written notice of the estimated expiration of the right to employment restoration and of the employee’s first scheduled workday.

Reduced Claim Duration

The bill lowers the minimum hours an employee must claim under WA PFML from eight hours to four hours. So, employees will now be able to use WA PFML to cover shorter absences than previously.

Expanded Benefits Continuation

Subject to some exceptions, employers must now provide health insurance continuation for any period of WA PFML, regardless of whether WA PFML is used concurrently with FMLA. Previously, the health benefit continuation requirement was contingent on the concurrent use of FMLA.

Notice and Poster Requirements

The bill specifies that notices to employees must include eligibility requirements, possible weekly benefits, application processes, employment protection rights, nondiscrimination rights, and other protections, as well as information pertaining to the filing of a complaint.

Updated Grants for Small Employers

The revised law allows small employers to apply for grants up to $3,000, increasing the grant amount available to small employers who incur significant costs for shorter term leaves. Notably, employers may receive no more than one grant for each employee on leave and a total of 10 grants per calendar year. Employers receiving these grants will be assessed premiums for three years from the date of receipt of the grant.

WASHINGTON PASSES STATE-LEVEL VERSION OF WARN ACT

Effective July 27, 2025, SB 5525 makes Washington the latest state to adopt a mini-Worker Adjustment and Retraining Notification Act (WA WARN) requiring employers with 50 or more full-time employees to give 60 days of advance notice to employees, unions, and the state for certain mass layoffs and business closures.

Highlights from the amended law that employers should know:

Employees on WA PFML Cannot Be Included in a Mass Layoff

Employees on PFML leave cannot be included in a mass layoff (50+ employees anywhere in Washington during any 30-day period), unless one of the following exceptions applies:

  • The layoff is caused by business circumstances that were not reasonably foreseeable at the time the notice would have been required
  • The layoff is due to a natural disaster
  • The layoff occurs at a construction project, and the affected employees were hired with the understanding that their employment was limited to a particular portion of the project
  • The layoff occurs at a multi-employer construction project, and the only affected employees are subject to a full union referral or dispatch system

Required Notice to Employees and the State Government Must Identify Affected Employees by Name

In addition, the required notice to the Washington Employment Security Department (WA ESD) must also include the addresses of the affected employees.

Business Closing Definition Broader Than Federal WARN

Unlike federal WARN, the definition of a business closing under WA WARN is not limited to employment losses within a 30-day or 90-day period. Under WA WARN, a “business closing” means “the permanent or temporary shutdown of a single site of employment of one or more facilities or operating units that will result in an employment loss for 50 or more employees, excluding part-time employees.”

Mass Layoff Definition Broader Than Federal WARN

Unlike federal WARN, mass layoffs under WA WARN are not limited to a single site of employment. So, a mass layoff would include the termination of 50 or more employees statewide within a 30-day period.

Further, there is no requirement under WA WARN for the layoff to affect a minimum percentage of the workforce. This is different from the federal WARN, where a mass layoff is defined as an employment loss at a single site of employment during any 30-day period for either: (1) at least 33% of full-time active employees and at least 50 employees or (2) 500 or more employees are affected.

No Notice Requirement to Chief Elected Official

Under the federal WARN, WA WARN does not require that employers send notice to the chief elected official. Instead, employers just need to notify unrepresented employees, unions, and the WA ESD.

Different Exceptions to WA WARN Than Federal WARN

Unlike the federal WARN, employers are not required to give notice if an exception applies for the entire 60-day notice window.

Under WA WARN, employers are not required to give notice if any of the following exceptions apply:

  • “Faltering company” exception: At the time the notice would have been required, (1) the employer was actively seeking capital or business, (2) the capital or business sought, if obtained, would have enabled the employer to avoid or postpone the business closing or mass layoff, and (3) the employer reasonably and in good faith believed that giving the notice would have precluded the employer from obtaining the needed capital or business
  • The mass layoff or business closing is caused by business circumstances that were not reasonably foreseeable at the time the notice would have been required; the unforeseeable business circumstances must be caused by a sudden, dramatic, and unexpected action or condition outside of the employer's control
  • The mass layoff or business closing is due to a natural disaster
  • The mass layoff occurs at (1) a construction project and the affected employees were hired with the understanding that their employment was limited to the duration of a particular portion of that construction project or (2) a multiemployer construction project, and the only affected employees are subject to a full union referral or dispatch system

Unlike the federal WARN, the faltering company exception applies to both mass layoffs and business closings.

LEAVE AND SAFETY ACCOMMODATIONS FOR VICTIMS OF HATE CRIMES

Effective January 1, 2026, SB 5101 amends Washington’s Domestic Violence Leave Law to give the same protections currently available to victims or family members of domestic violence, sexual assault, and stalking to victims of hate crimes. The amended law allows victims of hate crimes to take a reasonable amount of paid or unpaid leave to seek treatment, counseling, social services, or law enforcement or legal assistance. It also protects against retaliation, whether related to actual or perceived victim status.

Notably, because the Washington Minimum Wage Act references the Domestic Violence Leave Law to determine who may take paid sick leave, the amended law also functionally expands the reasons employees can use paid sick time to include hate crime-related leave.

A hate crime is defined as an assault on a person or their property because of the offender’s perception of the victim’s race, skin color, religion, ancestry, national origin, gender, sexual orientation, gender expression or identity, or mental, physical, or sensory disability. Victims of online and internet-based offenses are also protected under the amended law.

BROADENED PREGNANCY-RELATED ACCOMMODATIONS

Effective January 1, 2027, SB 5217 requires that lactation breaks must be paid, including time spent traveling to and from lactation locations. These breaks must be separate from and in addition to regular meal and rest breaks. Reasonable accommodations for pregnancy now include flexibility for scheduling postpartum medical visits in addition to prenatal visits covered under current law.

One significant change is the expansion of the employers covered by these requirements. SB 5217 expands coverage from employers with 15 or more employers to all employers with one or more employees.

The amended law also establishes a private right of action.

EXPANSION OF EMPLOYEE ACCESS TO PERSONNEL FILES

Effective July 27, 2025, HB 1308 expands employee access to their personnel files by clarifying requirements for employers and granting new rights to employees.

Key updates include:

  • “Personnel file” now includes job application records, performance evaluations, non-active or closed disciplinary records, leave and reasonable accommodation records, payroll records, and employment agreements
  • Employers must provide a copy of the personnel file within 21 calendar days of the request instead of within a “reasonable period”
  • Employers must provide a signed, written discharge statements within 21 days of a written request that includes the effective date of discharge, whether the employer had a reason for the discharge, and if so, the reasons
  • The amended law establishes a private right of action for violations, entitling employees or former employees to equitable relief, statutory damages, and reasonable attorneys’ fees and costs; the greater the delay in providing personnel files, the greater the statutory damages—statutory damages range from $250–$1,000.

WASHINGTON CALL CENTER JOBS ACT IMPOSES RESTRICTIONS ON EMPLOYERS MOVING CALL CENTERS ABROAD

Effective July 27, 2025, SB 5459 requires that employers notify the ESD at least 120 days before a relocation of a call center from Washington to a foreign country. This notice requirement also applies to employers intending to move a facility within a call center if it comprises at least 25% of total call volume averaged over 12 months. State agencies with a call center whose primary work is language interpretation services are exempt from the notice requirement.

Employers that do move call centers to foreign countries will be placed on an ESD list distributed to all state agencies and become ineligible for state grants for five years. Additionally, state agency contracts made after the effective date of this bill for purchases of call center services, except for interpreter services, must provide that the work performed by the contractor, its agents, or subcontractors be performed entirely within the United States.

Employers are covered by the act if they have 50 or more full-time employees or 50 or more workers who, together, work at least 1,500 hours per week, excluding overtime.

EXPANSION OF QUALIFYING REASONS FOR PAID SICK LEAVE FOR IMMIGRATION PROCEEDINGS

Effective July 27, 2025, HB 1875 allows employees to use paid sick leave for absences related to immigration proceedings, including proceedings involving the employee or a family member. Employers must accept verification documentation from an advocate, attorney, clergy member, or other professional, or an employee’s written letter stating that the employee or their family member is involving in a qualifying proceeding. Any verification document cannot include personally identifiable information about the person’s immigration status or underlying immigration protection.

EXPANSION OF FAIR CHANCE ACT

Effective July 1, 2026, HB 1747 expands Washington’s fair chance requirements. The prior law prevented employers from asking about applicant criminal records unless the employer initially determined an applicant was otherwise qualified. The amended law prohibits employers from obtaining information about an applicant’s criminal record unless the employer has extended a conditional offer of employment.

Read More >>

DRIVER’S LICENSE REQUIREMENTS ON JOB POSTINGS

Effective July 27, 2025, SB 5501 adds a new section to the Washington Equal Pay and Opportunities Act, limiting when employers can include the requirement for a valid driver’s license on a job posting. Employers may only require a valid driver’s license on a job posting if driving is an essential function of the position or related to a legitimate business purpose.

STRENGTHENED WORKPLACE SAFETY STANDARDS FOR ISOLATED EMPLOYEES

Effective January 1, 2026, HB 1524 amends the Washington Law Against Discrimination (WLAD) to add new safety standards for isolated employees.

Isolated Employee Defined

The amended law clarifies the definition of “isolated employee” to mean an employee who (1) performs work in an area where two or more coworkers, supervisors, or a combination thereof are unable to immediately respond to an emergency without being summoned by the employee or (2) spends at least 50% of her or his working hours without a supervisor or another coworker present and is employed as a janitor, security guard, hotel or motel housekeeper, or room service attendant.

Panic Button Requirements

Panic button requirements are updated to specify that they need to be able to help responders immediately locate the employee using the button and must be simple to use.

Training and Reporting Requirements

Employers must document completion of mandatory training and provide this documentation to the Washington State Department of Labor and Industries upon request.

CORRECTIONS TO WAGE AND SALARY DISCLOSURES

Effective July 27, 2025, SB 5408 amends the Equal Pay and Opportunity Act to clarify provisions regarding the required substance of job posting requirements and potential statutory damages awards, and to entitle employers to notice and an opportunity to correct any job posting before being subjected to penalties.

Read More >>

WORKPLACE VIOLENCE PREVENTION IN HEALTHCARE SETTINGS

Effective January 1, 2026, HB 1162 expands on the workplace violence prevention law previously passed in 2019 to require more regular and detailed reviews of workplace violence incidents in healthcare settings, including new reporting requirements and regular updates to safety plans.

UPDATED RECEIPT REQUIREMENTS FOR RIDE-SHARE COMPANIES

Effective July 1, 2026, HB 1332 requires ride-share companies (“transportation network companies”) to provide downloadable and searchable summary records of a driver’s per-trip receipts within three days of a driver’s request for the information. Per-trip and weekly receipt summary requirements are also updated to require information about what financial incentives, promotions, or bonuses apply to those trips.

Ride-share providers must also make information available to its drivers on which vehicles, described by make, model, and year, are eligible for each product class offered on its platform. Platforms must give drivers notice of at least 120 days if they plan to modify product classes.

HOSPITAL EMPLOYEES CAN WAIVE SOME MEAL AND REST BREAK REQUIREMENTS

Effective January 1, 2026, HB 1879 allows hospitals and employees to voluntarily agree to waive the following meal and rest break requirements:

  • Meal periods for shifts of less than eight hours
  • Second or third meal breaks for shifts longer than eight hours so long as one meal break is taken
  • Timing requirements for breaks so long as a meal break is taken no earlier than the third hour and no later than the second to last hour of a shift

Waivers must be agreed upon in advance of the first shift where a break is waived, and the waiver may be revoked at any time by either the employer or employee. Waiver agreements are required to be in writing or another electronic recordkeeping format.

RECOMMENDATIONS FOR EMPLOYERS

These new laws continue to expand employee protections in Washington state. Employers should take the following steps to meet their current obligations and prepare for the laws that will soon go into effect:

  • Reviewing and updating as necessary employee handbooks and policies to ensure compliance with the new laws
  • Training supervisors, managers, compliance personnel, human resources, and legal professionals on the implications of the new laws, including as to appropriate communications with applicants and employees asking for information on these topics