Perspectives

Minnesota Paid Family & Medical Leave: Final Steps to Be Fully Compliant in 2026

News WFJ Law Firm

Minnesota’s Paid Family & Medical Leave (PFML) program is no longer theoretical. With required employee notices already behind us, employers should be shifting their focus from planning to execution, consistency, and documentation.

If your organization completed the initial notice requirements before December 1, 2025, the following steps will help ensure you remain compliant throughout 2026.

Confirm Payroll is Working Exactly as Intended

At this stage, payroll deductions and employer contributions should already be determined. Now is the time to verify accuracy.

Double-check that:

  • Employee PFML deductions are being withheld correctly each pay period
  • Employer contributions match the required rate
  • Contributions stop at the applicable wage cap
  • Your payroll system clearly separates PFML from other deductions

Ensure Quarterly Reporting is Accurate and On Time

PFML requires ongoing reporting, not just payroll deductions.

Make sure your team has:

  • Established responsibility for submitting quarterly wage detail reports
  • Confirmed reporting aligns with existing unemployment insurance filings
  • Calendarized quarterly payment deadlines
  • A process for correcting errors quickly if discrepancies are identified

Late or inaccurate reporting can result in penalties-even if deductions were taken correctly.

Align Leave Administration with PFML Rules

Now that employees can actively use PFML benefits, internal processes must align with state administration.

Confirm your team understands:

  • Employees apply for PFML benefits through the state, not the employer
  • PFML runs separately from employer-paid benefits, but may run concurrently with:
    • FMLA
    • Employer PTO
    • Short-term disability (if applicable)
  • Job protection requirements, including reinstatement obligations
  • Health insurance continuation during PFML leave

Clear internal workflows prevent delays, inconsistent approvals, and employee frustration.

Update and Enforce Written Leave Policies

If it hasn’t been finalized already, it is critical now.

Your handbook and internal policies should:

  • Reference Minnesota PFML specifically
  • Clarify whether PTO must, may, or may not be used concurrently
  • Outline employee responsibilities for notice and documentation

Policies should reflect what your team is actually doing in practice-not aspirational language written months ago.

Maintain Proof of Required Notices

Although the December 1, 2025 notice deadline has passed, employers should still maintain documentation.

You should retain:

  • Copies of employee notices
  • Acknowledgments of receipt
  • Records showing notices were provided to new hires within required timelines
  • Proof that workplace posters remain displayed and accessible

If questioned later, documentation-not intent-will matter.

Reevaluate Private Plan Status (If Applicable)

If your organization opted for a private plan:

  • Confirm the plan remains approved and active
  • Ensure benefits still meet or exceed state requirements
  • Monitor renewal dates and state reporting obligations
  • Communicate clearly with employees about how benefits are accessed

If you are in the state plan, ensure leadership understands there is no “opt-out” after the fact without proper approval.

Prepare for Employee Questions and Edge Cases

As PFML becomes more widely used, questions will increase.

Be prepared to address:

  • Partial leave or intermittent leave scenarios
  • Coordination with remote or multi-state employees
  • Return-to-work timing and reinstatement issues
  • Overlapping medical and family leave situations

Having clear internal guidance now will prevent reactive decision-making later.

Final Compliance Check: What Should Be True Right Now

At this point, compliant employers should be able to say:

  • Payroll deductions and contributions are accurate
  • Reporting deadlines are assigned and tracked
  • Leave policies reflect PFML realities
  • Manager know when to escalate issues
  • Documentation is organized and retained
  • Employees know where to apply and what to expect

Bottom Line

Minnesota’s Paid Family & Medical Leave program is now an operational requirement-not a future project. Employers who focus on accuracy, consistency, and documentation will be best positioned to avoid compliance issues while supporting employees through qualifying leave.

If you need help reviewing policies, auditing payroll setup, or navigating complex leave coordination issues, working with experienced legal and compliance professionals can help ensure nothing is overlooked as PFML continues to roll out.

 

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