Saint Paul Labor Laws 2026: Complete HR Compliance Guide

Accurate as of May 5, 2026. This guide is informational and not legal advice. For specific situations, consult licensed Minnesota employment counsel.

Saint Paul runs one of the most active labor standards regimes of any city in the Upper Midwest. The Minimum Wage Ordinance pushed large employers to $16.37 an hour on January 1, 2026, the city Earned Sick and Safe Time amendments took effect November 16, 2025, and a new Wage Theft Ordinance turned the city's HREEO investigators loose on unpaid wage complaints starting January 1, 2025. None of that exists at the state level in the same form.

This guide is a single resource that pulls together what HR teams actually need to manage in 2026: the city Minimum Wage Ordinance under Chapter 224, the Earned Sick and Safe Time Ordinance under Chapter 233, the Wage Theft Ordinance, the Human Rights Ordinance under Chapter 183, plus the Minnesota statutes that overlay them, including the new Minnesota Paid Leave program that became effective January 1, 2026.

If your team handles complaints, leave requests, or pay disputes for Saint Paul workers, you can centralize the reporting and investigation workflow inside a dedicated employee relations platform rather than tracking every conversation in spreadsheets and email threads.

The 2026 Saint Paul Employment Law Updates HR Teams Should Know First

The most consequential 2026 changes for Saint Paul employers are concentrated in three buckets: city minimum wage step-ups, the November 2025 ESST amendments aligning Saint Paul with state ESST, and the first year of Minnesota Paid Leave benefits.

City minimum wage hits $16.37 for macro and large employers (101+ employees) effective January 1, 2026, with small employers (6-100) reaching the same rate on July 1, 2026.
Micro employer rate climbs to $14.25 on July 1, 2026, on a glide path to the full city rate by July 1, 2028.
ESST documentation threshold tightened to two consecutive scheduled workdays starting November 16, 2025, down from the prior three-day rule.
Harassment added as a standalone qualifying use for Saint Paul ESST safe time, even though state ESST does not list harassment as a separate category.
Minnesota Paid Leave benefits became available January 1, 2026, with a 0.88% combined premium and the first contributions due April 30, 2026.
Saint Paul Wage Theft Ordinance entered its second year of HREEO enforcement, with a two-year statute of limitations on city complaints.
Minnesota state minimum wage moved to $11.41 per hour on January 1, 2026 for all employers under the unified state rate.

Each of these is detailed in the sections that follow.

Saint Paul Minimum Wage Under Chapter 224

The Saint Paul Minimum Wage Ordinance, codified at Chapter 224, sets a city wage floor that varies by employer size. The ordinance covers any employee who performs work within the geographic boundaries of Saint Paul. Wages include salary, hourly pay, piece rate pay, commissions, and non-discretionary performance bonuses. Employer payments toward medical benefits and tips do not count toward the wage.

Minnesota does not allow a tip credit. Tipped employees in Saint Paul must be paid the full applicable city minimum wage before tips.

What Are the 2026 Saint Paul Minimum Wage Rates by Employer Size?

The city published 2026 rates in November 2025. Macro and large employers transition first, on January 1, with small employers catching up six months later.

Macro businesses (10,001+ employees) and the City of Saint Paul: $16.37 effective January 1, 2026.
Large businesses (101–10,000 employees): $16.37 effective January 1, 2026.
Small businesses (6–100 employees): $15.00 from July 1, 2025, rising to $16.37 on July 1, 2026.
Micro businesses (5 or fewer employees): $13.25 from July 1, 2025, rising to $14.25 on July 1, 2026.

Annual increases starting in 2027 are calculated by the Commissioner of the Minnesota Department of Labor and Industry under Minn. Stat. § 177.24, applied to the city rate. Saint Paul has committed to a $15 minimum for all employers, including micro, by 2027 and a fully indexed micro rate by 2028.

How Does Saint Paul Count Employees for the Tier Determination?

Saint Paul counts all employees of the business, not just those who perform work in the city. The count includes full-time, part-time, jointly employed, and temporary employees. The tier determination drives the rate that applies to the workers the employer schedules in Saint Paul. Multi-state employers that staff a small Saint Paul retail location often land in the macro or large tier because of headcount elsewhere.

Joint-employer relationships, including franchise structures and staffing agency arrangements, can push a business into a higher tier. This is the most common compliance trap when a national franchisor's headcount is aggregated with the local franchisee operation.

What Is the Saint Paul Youth and Training Wage?

Saint Paul applies a reduced rate for workers under 18 and during the first 90 days of employment for workers under 20. The rate tracks the state youth wage and adjusts on July 1 each year. For July 1, 2026, the youth and training wage moves to 85% of the city minimum wage, rounded to the nearest nickel, replacing the prior fixed schedule that had reached $12.75 on July 1, 2025. Workers convert to the full city rate on their 18th birthday or after their first 90 days of employment, whichever comes first.

How Does the State Minimum Wage Compare to Saint Paul's Rate?

Minnesota's state minimum wage is significantly lower than the city rate. Effective January 1, 2026, the state minimum wage is $11.41 per hour for all employers in Minnesota under a unified rate, replacing the previous two-tier system that had distinguished between large and small employers. The 90-day training wage for workers under 20 at the state level is $9.31. These rates only apply to work performed outside Saint Paul, Minneapolis, and other municipalities with their own ordinances.

Does Saint Paul Require Pay for Travel Time and On-Call Time?

Saint Paul follows Minnesota state rules on compensable time. Travel between job sites during the workday is paid time. The first commute of the day and the last commute home are not. On-call time spent on the employer's premises or otherwise restricted to a degree that the employee cannot use the time for personal purposes is generally compensable. State rules under Minn. Stat. § 177 govern the analysis. For a deeper read on local pay enforcement, the city's broader guide to Minneapolis labor laws covers the parallel ordinance for the other Twin City.

The Saint Paul Wage Theft Ordinance

Saint Paul's Wage Theft Ordinance took effect January 1, 2025. The ordinance does not create new substantive obligations on what employers must pay; instead, it gives the Department of Human Rights and Equal Economic Opportunity (HREEO) Labor Standards Division enforcement authority to investigate allegations that an employer failed to pay what state, federal, or city law requires.

What Counts as Wage Theft Under the Ordinance?

The ordinance treats wage theft broadly. It includes any failure to pay an employee what they are legally owed.

Below minimum wage: paying any rate lower than the applicable city or state minimum.
Unpaid overtime: failing to pay time and one-half for hours over 48 in a workweek under Minnesota law (or the FLSA's 40-hour threshold for FLSA-covered employers).
Off-the-clock work: requiring or allowing work without pay.
Denied breaks: failure to provide meal or rest periods required by Minnesota law.
Misclassification: treating an employee as an independent contractor when the worker meets the employee test.
Withholding tips: taking gratuities or imposing involuntary tip pools.
Unpaid fringe benefits: failing to pay benefits that are part of the wage agreement.
Illegal deductions: deductions not authorized by law or written employee consent.

What Is Saint Paul's Wage Notice Requirement?

Beginning January 1, 2025, employers must give every new hire an Employee Wage Notice at the start of employment, and they must provide the notice to current employees if the information was not previously given. The notice must include the city minimum wage rates and the employee's entitlement to those rates, a statement that gratuity sharing is voluntary where applicable, and the overtime policy that applies to the position, including when overtime is paid and at what rate.

Annually, employers must remind employees of their rights under the ordinance. Employers must also post a notice of employee rights at the worksite, in English plus any other language spoken by employees. Where physical posting is not practical, electronic distribution to each employee or posting on a web or app-based platform satisfies the obligation. The notice of rights must be included in any employee handbook the employer distributes.

Who Can File a Wage Theft Complaint With HREEO?

Anyone may file a complaint, including employees, third parties, businesses, and unions. HREEO does not ask about an employee's immigration status. The statute of limitations runs two years from the last incident of wage theft. Complaints can be filed by phone at 651-266-8966 or by email at LaborStandards@stpaul.gov. Anonymous reports are accepted and investigated when the facts permit.

What Penalties Does HREEO Impose for Wage Theft?

Remedies under the ordinance can include reinstatement of a wrongfully terminated worker, back pay, liquidated damages, and debarment from city contracts. The administrative rules adopted in February 2025 set the procedures HREEO follows when investigating, attempting conciliation, and assessing penalties. A consistent record-keeping practice paired with structured HR case management reduces the likelihood that a complaint becomes a finding because investigators look at documentation first.

Saint Paul Earned Sick and Safe Time Under Chapter 233

Saint Paul was one of the earliest Minnesota cities to adopt a paid sick leave ordinance. The 2014 ordinance has now been amended multiple times to align with the state Earned Sick and Safe Time law that took effect January 1, 2024, and the most recent round of amendments took effect November 16, 2025.

Who Is Covered by Saint Paul ESST?

Coverage extends to any employee who works within the geographic boundaries of Saint Paul for at least 80 hours in a year. The 80-hour threshold counts time at any business activity within city limits, regardless of whether the employer is based in Saint Paul. Full-time, part-time, temporary, and paid on-call workers all count once they cross the threshold.

How Do Employees Accrue ESST?

Employees accrue one hour of ESST for every 30 hours worked within Saint Paul. The accrual cap is 48 hours per year, with up to 80 hours of accrued time carried into the following year. Employers can choose to frontload time instead. The frontload amount must be at least 48 hours per year if unused time is paid out at the end of the year, or at least 80 hours per year if no payout occurs.

What Can Employees Use ESST For?

Saint Paul recognizes both sick and safe time uses. Sick uses cover the employee's or a family member's mental or physical illness, injury, or health condition; preventive medical care; and care during a public emergency that closes the workplace or an employee's child's school for health reasons. Safe uses cover absences related to domestic abuse, sexual assault, stalking, and now harassment as a standalone qualifying use after the November 2025 amendments. The harassment expansion is a Saint Paul-specific protection that does not appear on the state ESST list.

Can an Employer Require Documentation for an ESST Absence?

After the November 16, 2025 amendments, employers can request reasonable documentation only after an employee is absent for more than two consecutive scheduled workdays. The previous threshold was three consecutive days. Employers cannot require disclosure of the specific medical condition, the specific reason for safe time, or sensitive details about domestic abuse, sexual assault, harassment, or stalking. The notice that ESST is being used is sufficient.

What Are the Time-Increment Rules for ESST Use?

Employers must allow ESST in increments as small as 15 minutes, but they cannot require an employee to use more than four hours of ESST at a time. This rule prevents an employer from forcing an employee to burn an entire day of ESST for a short medical appointment.

How Does Saint Paul ESST Interact With Minnesota State ESST?

Minnesota's statewide ESST law took effect January 1, 2024 and covers all Minnesota employers. The state minimum is one hour of ESST for every 30 hours worked, with an accrual cap of 48 hours and a carryover cap of 80 hours. Saint Paul's ordinance is broader in two specific ways: it adds harassment as a standalone safe time use and tightens the documentation threshold to two consecutive days. Where the city ordinance is more generous, the city rule applies. Where it is silent, state ESST controls. Employers running policies for Saint Paul workers should write to the city standard so a single policy works in both jurisdictions. The same approach handled by employers in our broader Minnesota labor laws guide covers the state baseline in detail.

Minnesota Paid Leave: First Benefits Available in 2026

Minnesota Paid Leave is a state-administered family and medical leave insurance program that became effective January 1, 2026. The program covers employees in Saint Paul as fully as anywhere else in the state. It is funded by a payroll premium and pays partial wage replacement during qualifying absences.

What Is the 2026 Minnesota Paid Leave Premium?

The combined premium rate for 2026 is 0.88% of wages, allocated as 0.61% for medical leave and 0.27% for family leave. Premiums apply to wages up to $185,000. Small employers with 30 or fewer workers and an average wage at or below 150% of the statewide average wage pay a reduced rate of 0.66%.

Employers must pay at least 50% of the premium and may deduct the remainder from employee wages. The standard split is therefore 0.44% employer and 0.44% employee. The first quarterly premium payment was due April 30, 2026.

How Much Leave Does Minnesota Paid Leave Provide?

Eligible employees can take up to 12 weeks of medical leave in a benefit year for their own serious health condition and up to 12 weeks of family leave for caregiving, bonding with a new child, military exigency, or safety leave. Combined, an employee can take up to 20 weeks total in a benefit year if they qualify for both. Wage replacement is graduated: a higher percentage on the first wages and a lower percentage on the higher wages, with a state-set maximum weekly benefit.

How Does Minnesota Paid Leave Coordinate With Saint Paul ESST and Minnesota ESST?

Paid Leave covers longer absences. ESST covers short, foreseeable, and unforeseeable absences. They do not stack for the same hours. The most common interaction is an employee using ESST for the first day or two of a longer absence (covering the Paid Leave waiting period) and then transitioning to Paid Leave benefits. Employers can require coordination with available paid time off only as a top-up arrangement, not as a substitute for state benefits.

Pay Transparency in Minnesota Job Postings

Minnesota's pay transparency law took effect January 1, 2025. The statute is codified at Minn. Stat. § 181.173. Saint Paul employers with operations elsewhere in the state are covered if they meet the threshold.

Who Is Covered by Minnesota's Pay Transparency Law?

The law applies to employers with 30 or more employees at one or more sites in Minnesota. Coverage extends to private and public sector employers, including cities. The law requires job postings, electronic or print, internal or external, to include specific pay and benefit information.

What Must a Compliant Saint Paul Job Posting Include?

Salary range: a good faith estimate of the minimum and maximum compensation. Open-ended ranges are prohibited.
Fixed pay rate: if no range applies, the specific fixed rate the position pays.
General description of benefits: health, retirement, paid leave, and other benefits offered for the position.
Other compensation: bonuses, commissions, equity, or stipends that apply.

Does the Law Apply to Third-Party Recruiters and Job Boards?

Yes. If a Saint Paul employer uses an executive search firm or a third-party recruiting partner, the disclosure obligations follow the posting. Postings on third-party job boards must also include the required information. The Minnesota Department of Labor and Industry and the Minnesota Attorney General have enforcement authority.

Saint Paul Human Rights Ordinance Under Chapter 183

The Saint Paul Human Rights Ordinance, codified at Chapter 183, prohibits employment discrimination on the basis of a wide list of protected classes. The ordinance is enforced by the HREEO Department's Human Rights Investigations division, separate from the Labor Standards Division.

Which Protected Classes Does Chapter 183 Cover?

Race
Color
National origin
Disability
Sex
Gender identity
Sexual or affectional orientation
Religion
Creed
Age
Marital status
Familial status
Ancestry
Status with regard to public assistance

Employers, labor unions, and employment agencies cannot make hiring, firing, promotion, or compensation decisions based on a protected class. The ordinance also covers retaliation for opposing discrimination or participating in an investigation.

How Does Chapter 183 Compare to the Minnesota Human Rights Act?

Chapter 183 mirrors most of the Minnesota Human Rights Act (MHRA, Minn. Stat. Chapter 363A) but is enforced locally. Aggrieved employees can file with HREEO, the Minnesota Department of Human Rights, or the EEOC, depending on the claim. Saint Paul HREEO has cross-filing arrangements with state agencies. Most Saint Paul claims are filed with HREEO when the alleged conduct occurred within city limits and the employer has a substantial city presence.

What Does the Minnesota CROWN Act Add for Hair-Based Discrimination?

Minnesota's CROWN Act took effect August 1, 2023. The Act amended the MHRA to define "race" as including "traits associated with race, including but not limited to hair texture and hair styles such as braids, locs and twists." The amendment provides explicit protection from any adverse employment action, discipline, failure to promote, termination, or harassment, based on hair texture or style associated with the person's race. Saint Paul HREEO incorporates the CROWN Act through its enforcement of city protections that align with the MHRA.

Minnesota Anti-Harassment and Retaliation Standards

In addition to Title VII and the MHRA, Saint Paul employers must follow specific Minnesota statutes governing harassment and retaliation. The state's harassment standard moved away from the federal "severe or pervasive" test in 2023 when the legislature amended the MHRA to clarify that conduct does not need to be severe or pervasive to constitute harassment.

What Is the Minnesota Workplace Harassment Standard?

Conduct constitutes harassment under the MHRA if it is based on a protected class and either (1) submission to or rejection of the conduct is made a term or condition of employment, (2) submission to or rejection of the conduct is used as a basis for an employment decision, or (3) the conduct has the purpose or effect of substantially interfering with an individual's employment or creating an intimidating, hostile, or offensive work environment. Minnesota explicitly rejects a "severe or pervasive" gating threshold for hostile work environment claims. The change makes Minnesota harassment claims more accessible to plaintiffs than parallel federal claims.

How Should Saint Paul Employers Document Investigations?

Document the complaint as it was received, the steps the employer took to investigate, the witnesses interviewed, the evidence reviewed, the findings reached, and the action taken. Keep complaint records separate from the personnel file when possible. A neutral investigator (internal or external) helps protect privilege and credibility. Many Saint Paul employers run intake and investigation through a single platform, see how a structured investigations management workflow handles the documentation chain. The HR Dive playbook on handling sexual harassment in the workplace covers the practical decisions investigators face when allegations involve senior leaders.

What Retaliation Protections Apply in Saint Paul?

Minnesota and Saint Paul both prohibit retaliation against employees who report unlawful conduct, participate in investigations, or refuse to participate in unlawful activity. Retaliation can include termination, demotion, schedule changes, reduction in hours, exclusion from training, and any other materially adverse action. Saint Paul's ESST and Wage Theft ordinances each contain explicit retaliation prohibitions. The Minnesota Whistleblower Act (Minn. Stat. § 181.932) provides a private cause of action for employees who report a violation of state, federal, or common law in good faith.

Pregnancy, Parental Leave, and Caregiver Protections

Minnesota provides several pregnancy-related protections that apply to Saint Paul employers. The state has stacked protections beyond federal law.

What Pregnancy and Parental Leave Rules Apply?

Minnesota Pregnancy and Parental Leave Act (Minn. Stat. § 181.941): 12 weeks of unpaid, job-protected leave for parents covered by the statute, with continuation of group insurance.
Minnesota Paid Leave: family leave includes 12 weeks for bonding with a new child.
Pregnancy accommodations (Minn. Stat. § 181.939): reasonable accommodations including longer breaks, seating, and limits on heavy lifting; no undue hardship defense for the listed accommodations.
Lactation breaks (Minn. Stat. § 181.939): reasonable break time and a private space (not a bathroom) for nursing employees, paid in many cases.

How Do These Stack With FMLA and the Federal PWFA?

FMLA provides 12 weeks of unpaid, job-protected leave for serious health conditions, bonding, and qualifying exigency. The federal Pregnant Workers Fairness Act (PWFA), effective June 27, 2023, requires reasonable accommodations for pregnancy, childbirth, and related medical conditions. State protections sit on top of these federal floors. Saint Paul employers should run pregnancy-related leave through FMLA, Minnesota PFML state benefits, the state pregnancy accommodation rule, and the federal PWFA at the same time, with the most generous rule applying for any specific need.

Independent Contractor Classification in Minnesota

Minnesota uses different classification tests depending on the law at issue. Wage and hour, unemployment insurance, workers' compensation, and tax all have distinct frameworks.

Which Test Applies for Wage and Hour Claims?

For Minnesota wage and hour claims, courts apply a multifactor "economic realities" analysis that examines the degree of control, the worker's opportunity for profit and loss, investment in tools and equipment, the permanence of the relationship, and whether the work is integral to the business. The Minnesota Department of Labor and Industry and HREEO both use a similar analysis.

What About the Construction Industry?

Minnesota has a stricter test for the construction industry under Minn. Stat. § 181.723. Workers in construction are presumed to be employees unless the hiring entity can show the worker meets specific independent contractor criteria, including operating a separate business, maintaining a separate place of business, holding a federal employer ID number, and entering into a written contract.

What Are the Penalties for Misclassification?

Misclassification can trigger unpaid overtime, ESST liability, unpaid Paid Leave premiums, missed minimum wage, unemployment insurance back-assessments, and personal liability under the Minnesota Wage Theft Act. The 2019 state Wage Theft Act (Minn. Stat. § 181.03) added criminal penalties for intentional wage theft, including misclassification used to evade wage obligations. Repeat or systematic misclassification is one of the easier violations for HREEO to substantiate because the documentation trail tends to expose itself.

Hiring, Background Checks, and Salary History in Saint Paul

Saint Paul follows Minnesota's framework for hiring rules. The state has banned the box for both public and private employers and bars salary history inquiries for state agencies, with private-sector restrictions limited to certain practices.

What Does Minnesota's Ban-the-Box Rule Require?

Minnesota's ban-the-box law (Minn. Stat. § 364.021) prohibits public employers from inquiring about an applicant's criminal history until the applicant is selected for an interview, or, if no interview is conducted, until a conditional offer of employment is made. The same rules apply to private employers under Minn. Stat. § 364.021(b), private employers cannot inquire into or consider a job applicant's criminal record until the applicant has been selected for an interview or, if no interview is conducted, until a conditional offer is made. Saint Paul's HREEO handles complaints involving city contractors and city government applications, while private-sector complaints flow to the Minnesota Department of Human Rights.

What FCRA and Minnesota Background Check Rules Apply?

Background check vendors are consumer reporting agencies under the federal Fair Credit Reporting Act (FCRA). Saint Paul employers must give the standalone disclosure and obtain written authorization before procuring a consumer report. Adverse action procedures (pre-adverse notice with copy of the report and FCRA summary, then final adverse action notice) apply to any employment denial based on a report.

Can Employers Require Driver's Licenses or Credit Reports?

Minnesota allows driver's license requirements only when driving is a bona fide job requirement. Credit reports can be used only when the position involves financial responsibilities, executive authority, or fiduciary duties, under Minn. Stat. § 13.40 and FCRA. Saint Paul has not added local restrictions beyond state law in this area, but employers using credit checks should document the position-specific basis.

Off-Duty Conduct, Cannabis, and Privacy Protections

Minnesota legalized adult-use cannabis effective August 1, 2023, with broad employee protections layered on top of standard at-will employment.

Can Saint Paul Employers Drug Test for Cannabis?

Minnesota's Drug and Alcohol Testing in the Workplace Act (DATWA, Minn. Stat. §§ 181.950–181.957) governs all employer drug testing. The state cannabis legalization amended DATWA to limit cannabis testing in most circumstances. Pre-employment cannabis testing is generally prohibited, except for safety-sensitive positions (peace officers, firefighters, transportation workers under federal mandate, certain healthcare positions, positions providing direct patient care). Reasonable suspicion testing remains permissible if the employer has DATWA-compliant policies and documents the suspicion. Random testing is allowed only for safety-sensitive positions and certain positions covered by collective bargaining.

What Off-Duty Conduct Is Protected?

Minn. Stat. § 181.938 protects employees who use lawful consumable products (including alcohol, tobacco, and now cannabis) off the employer's premises during nonworking hours. Saint Paul employers cannot discipline an employee for lawful off-duty cannabis use unless the employer can demonstrate a bona fide occupational qualification, a conflict with federal funding requirements, or a position that is safety-sensitive under state rules.

Workers' Compensation and Workplace Safety

Minnesota OSHA (MNOSHA) regulates workplace safety in Saint Paul. Minnesota is a state-plan OSHA state, meaning MNOSHA enforces both federal OSHA standards and state-specific rules.

What Are Minnesota's Workplace Violence Prevention Standards?

Minnesota does not have a single statute equivalent to California's SB 553 workplace violence prevention plan rule. MNOSHA enforces general duty clause obligations to provide a workplace free from recognized hazards, which includes violence risks in healthcare, retail, and other settings. Minnesota healthcare facilities have specific violence prevention obligations under Minn. Stat. § 144.566. The Minnesota Department of Health and MNOSHA share enforcement.

What Are Saint Paul's Heat and Cold Standards?

MNOSHA enforces a heat-stress standard under Minn. R. 5205.0110 that sets exposure limits and requires employer action when limits are reached. Saint Paul's outdoor industries (construction, agriculture-adjacent work, parks, public works) must follow the rule. Cold-stress hazards trigger general duty clause obligations and standard PPE requirements. Indoor warehouse, restaurant, and laundry settings frequently fall under heat-stress monitoring during summer months.

How Do Workers' Compensation Claims Work?

Minnesota workers' compensation is administered by the Department of Labor and Industry. Employers must report injuries within 10 days when the injury results in lost time of more than three calendar days, death, or permanent partial disability. The state's no-fault system pays medical benefits, wage-loss benefits, and permanent disability benefits. Employees can also bring retaliation claims under Minn. Stat. § 176.82 if they are disciplined or terminated for filing a workers' compensation claim. The connection between workers' comp claims and underlying workplace culture issues is one reason an anonymous employee feedback channel matters: many serious safety issues are reported only when reporters believe they will not be retaliated against.

Minnesota Restrictive Covenants After the 2023 Non-Compete Ban

Minnesota became one of the first states to ban most employee non-competes when Governor Walz signed legislation effective July 1, 2023. The statute is codified at Minn. Stat. § 181.988. Saint Paul employers should treat post-employment non-competes as unenforceable for any agreement signed on or after that date.

What Does Minn. Stat. § 181.988 Actually Prohibit?

The statute defines a covenant not to compete as an agreement that restricts an employee, after the end of employment, from performing work for another employer for a specified period, in a specified geography, or in a similar capacity. The law applies to employees and independent contractors and contains no income threshold. Two narrow carveouts remain: agreements connected to the sale of a business and agreements connected to the dissolution of a business.

What Restrictive Covenants Are Still Allowed?

Nondisclosure agreements: still permitted to protect confidential information.
Trade secret agreements: still permitted under Minn. Stat. Chapter 325C.
Non-solicitation of clients: still permitted, including agreements limiting use of client or contact lists.
Non-solicitation of employees: still permitted, but should be drafted narrowly.
Confidentiality covenants in severance: still permitted.

What Choice-of-Law Protections Did the Statute Add?

The law prohibits Saint Paul employers from requiring an employee who primarily resides and works in Minnesota to agree, as a condition of employment, that disputes will be adjudicated outside Minnesota or that Minnesota substantive protections will be waived. Out-of-state forum selection clauses and out-of-state choice-of-law clauses tied to non-compete or related provisions are not enforceable against a Minnesota-based employee.

Smaller Leave Categories Under Minnesota Law

Beyond ESST, Paid Leave, and the federal FMLA, Minnesota recognizes several smaller leave categories that frequently surface in HR conversations. Saint Paul employers must coordinate them carefully because the categories can stack.

What Is Minnesota's School Activities Leave?

Under Minn. Stat. § 181.9412, Saint Paul employers must grant up to 16 hours of leave during any 12-month period for an employee to attend school conferences or school-related activities related to the employee's child, when the conferences or activities cannot be scheduled outside work hours. The leave can be unpaid, but the employee may substitute accrued paid vacation or other paid leave. The 16-hour cap applies per child. Pre-K, child care, and special education program activities all qualify.

What Are the Bone Marrow and Organ Donation Leave Rules?

Under Minn. Stat. §§ 181.945 and 181.9456, employers with 20 or more employees at one or more sites must grant paid leaves of absence up to 40 work hours to an employee donating bone marrow or an organ. The combined length is determined by the employee but cannot exceed 40 work hours per donation unless the employer agrees to more. Employers can require verification by a physician of the purpose and length of the leave. If a medical determination later concludes the employee does not qualify as a donor, the paid leave already granted before that determination is not forfeited.

What Voting Time Off Must Saint Paul Employers Provide?

Under Minn. Stat. § 204C.04, every Saint Paul employee who is eligible to vote has the right to be absent from work for the time necessary to appear at the polling place, cast a ballot, and return to work. The time off must be paid for time falling within scheduled work hours. The employer cannot require employees to use personal leave or vacation. The employer can ask the employee to communicate timing and can request employees coordinate absences to limit workplace disruption. Violations are misdemeanors under state law.

What Other Leave Categories Apply?

Jury duty leave: Minn. Stat. § 593.50 protects employees from termination or coercion for jury service. Pay during jury service is not required.
Witness leave: employees subpoenaed to appear in court receive job-protected leave.
Crime victim leave: employees attending criminal proceedings as victims have job protection under state law.
Military leave: Minnesota's military leave statute under Minn. Stat. §§ 192.261 and 192.262 layers on top of federal USERRA, including pay differential rules for state employees.
Pregnancy and parental leave: 12 weeks under Minn. Stat. § 181.941, with pregnancy accommodations under Minn. Stat. § 181.939.
Safety leave: ESST safe time covers domestic abuse, sexual assault, stalking, and (in Saint Paul) harassment.

Mass Layoffs and Plant Closings

Minnesota does not have a state mini-WARN that adds substantively to the federal WARN Act, but the state has notification requirements that interact with federal WARN obligations.

When Does Federal WARN Apply to Saint Paul Employers?

Federal WARN applies to employers with 100 or more full-time employees. Covered events are plant closings affecting 50 or more employees at a single site or mass layoffs of 500 or more, or 50–499 employees if they constitute at least 33% of the workforce. The notice period is 60 days to affected employees, the chief elected official of the local government, and the state dislocated worker unit (the Minnesota Department of Employment and Economic Development).

Are There Minnesota-Specific Notification Rules?

Minnesota's CEED (Closing and Expansion Efficient Discussion) requirements layer on top of federal WARN. The Minnesota Department of Employment and Economic Development collects WARN notices and triggers rapid response services. Failure to provide WARN notice can result in payment of wages and benefits to affected employees for the period of violation, up to 60 days. Saint Paul does not impose city-specific layoff notice rules beyond state and federal law.

Final Paychecks and Wage Statements

Minnesota wage statement and final paycheck rules apply to Saint Paul employers. The Minnesota Wage Theft Act of 2019 made wage statement obligations a focal point for state and local enforcement.

When Is the Final Paycheck Due in Minnesota?

Termination by employer: all earned wages and commissions due immediately on demand. If the employee is not paid within 24 hours of demand, the employee is entitled to penalties under Minn. Stat. § 181.13.
Voluntary quit: due on the next regular payday, but not more than 20 days after the employee leaves.
Penalty for late final pay: the employer owes the employee's average daily earnings for each day the wages remain unpaid, up to 15 days.

What Must a Compliant Wage Statement Include?

Minn. Stat. § 181.032 requires every wage statement to include the employee's name, hours worked, rate of pay, gross wages, allowable deductions, net pay, the dates covered by the pay period, employer name and address, employer telephone, and employer email or other electronic contact. Saint Paul's Wage Notice ordinance adds the requirement that the initial Employee Wage Notice cover city minimum wage rates, gratuity sharing language, and overtime policy. The two requirements are administered separately but work together.

Saint Paul Industry-Specific Rules

Some Saint Paul employers face industry-specific obligations beyond the general framework. Three areas are common.

What Rules Apply to City Contractors?

Saint Paul's prevailing wage requirements apply to most public works projects under the city's Living Wage and Vendor Outreach Program. Contractors must submit certified payrolls, provide proof of compliance with the Minimum Wage Ordinance, and meet local hire targets where applicable. Apprenticeship participation is required for certain construction trades on city-funded projects.

What Rules Apply to Hospitality?

Hospitality employers in Saint Paul are particularly exposed to wage theft and tip-handling claims. The Minnesota Tip Act (Minn. Stat. § 177.24) prohibits employers from requiring tipped employees to share gratuities with the employer or any non-tipped employee. Saint Paul's Wage Notice obligation requires the employer to disclose that tip-sharing is voluntary. HREEO has prioritized hospitality enforcement during the first year of the Wage Theft Ordinance.

What About Healthcare and Long-Term Care?

Minnesota has specific staffing, training, and reporting rules for healthcare under Minn. Stat. Chapter 144 and the Nursing Home Bill of Rights. The Minnesota Nursing Home Workforce Standards Board, established in 2023, sets industry-wide minimum standards for long-term care. Saint Paul healthcare employers must follow both the state framework and the city ESST and Wage Theft ordinances. The Minnesota Department of Health enforces health-specific obligations, while HREEO handles ESST and wage theft complaints.

Saint Paul Recordkeeping Obligations

Minnesota and Saint Paul both impose recordkeeping rules. The combined record-keeping load is among the most detailed of any U.S. city.

What Records Must Saint Paul Employers Keep?

Time and pay records: hours worked each day and workweek, wages paid, deductions, tips received, tip pool details, three years under state law and the Wage Theft Ordinance.
ESST records: hours worked, ESST accrued, ESST used, frontload election, payout decisions, three years.
Wage Notice acknowledgments: the Employee Wage Notice and any subsequent updates with the employee's signed acknowledgment, three years.
Personnel records: applications, performance reviews, disciplinary records, termination records, at least three years; longer if litigation is foreseeable.
Investigation records: complaint intake forms, witness statements, evidence reviewed, findings, and outcomes, separately from personnel files.
I-9 records: three years after hire or one year after termination, whichever is later.

What Are the Penalties for Recordkeeping Failures?

HREEO can issue civil penalties for ESST and wage theft recordkeeping failures, with amounts set under the administrative rules. The Minnesota Department of Labor and Industry can issue parallel state penalties. Recordkeeping failures often surface during routine investigations and convert what would have been a small dispute into a larger administrative finding.

Where to File Complaints in Saint Paul

Saint Paul HREEO handles labor standards and human rights complaints involving Saint Paul employers. State agencies have parallel jurisdiction for many issues.

Who Enforces the Minimum Wage and ESST Ordinances?

HREEO Labor Standards Division at 651-266-8966 or laborstandards@stpaul.gov enforces Saint Paul's Minimum Wage, ESST, and Wage Theft ordinances. Complaints can also be filed with the Minnesota Department of Labor and Industry for state-level violations of state ESST and minimum wage. Many complaints are dual-filed.

Who Enforces Discrimination Claims?

HREEO Human Rights Investigations enforces Chapter 183 employment discrimination claims. The Minnesota Department of Human Rights enforces the MHRA. The U.S. EEOC enforces federal Title VII, ADA, ADEA, GINA, and PWFA. Most discrimination claims are filed jointly under work-share agreements between the agencies.

What About Workers' Compensation and OSHA?

Workers' compensation claims go to the Minnesota Department of Labor and Industry's Workers' Compensation Division. MNOSHA, also within DLI, handles workplace safety complaints. Both have anonymous complaint mechanisms for workers concerned about retaliation.

Saint Paul vs. Minneapolis: Why Twin Cities Coverage Is Not One-Size-Fits-All

Many employers operate in both Saint Paul and Minneapolis. The two cities have similar but not identical labor standards. Treating them as a single set of rules is one of the most common compliance shortcuts that backfires.

How Do the Two Cities Compare on Minimum Wage?

Both cities are above the Minnesota state minimum, but their structures differ. Minneapolis has a single citywide rate for all employers as of mid-2024 forward. Saint Paul still maintains a tiered system based on employer size, with macro and large at $16.37 effective January 1, 2026, small at $16.37 effective July 1, 2026, and micro at $14.25 effective July 1, 2026. Saint Paul will not unify the rate until 2028. Employers operating in both cities should compute the higher of the two for any work performed in either city.

How Do the Two Cities Compare on Wage Theft Enforcement?

Saint Paul adopted the city Wage Theft Ordinance effective January 1, 2025, with HREEO enforcement. Minneapolis enforces wage theft through its Department of Civil Rights. Investigation processes and penalty structures are similar but not identical. Multi-city employers should expect parallel scrutiny.

Saint Paul Hospitality Industry Compliance

Restaurants, hotels, breweries, and event venues are concentrated in downtown Saint Paul and along University Avenue, the West Seventh Street corridor, and Grand Avenue. The hospitality industry is the most active enforcement area for HREEO. Three rules drive most violations.

What Tip-Pooling Rules Apply in Saint Paul?

Minn. Stat. § 177.24 prohibits employers from requiring tipped employees to share gratuities with the employer or any non-tipped employee. Tip-sharing among tipped employees is allowed if voluntary. The Wage Notice ordinance requires the employer to disclose to each new tipped employee that gratuity sharing is voluntary. Mandatory pooling that includes back-of-house non-tipped staff is a violation.

What Service Charge Rules Apply?

Minnesota law requires that any mandatory service charge added to a customer's bill be disclosed to the customer as not being a gratuity. If the charge is treated as a gratuity, the full amount must be paid to the tipped employees who served the customer. Saint Paul HREEO investigators have actively reviewed service charge practices in restaurants and hotels during the first year of Wage Theft Ordinance enforcement.

What ESST Rules Apply to Variable-Schedule Hospitality Workers?

Hospitality workers often have schedules that fluctuate week to week. Saint Paul ESST accrues based on hours worked, so variable schedules track hours rather than full-time equivalents. Workers who pick up shifts at multiple locations of the same employer have their accrual aggregated across the employer. Workers who work at multiple unrelated employers accrue separately at each. Documentation should map ESST balances to specific worker IDs across the entire employer footprint.

Saint Paul Annual Compliance Calendar

A predictable annual rhythm reduces failure risk. Saint Paul HR teams generally manage a calendar like the one below.

What Should Saint Paul Employers Do Each Quarter?

Q1 (January through March): apply new January 1 minimum wage rates for macro and large employers, file the first Minnesota Paid Leave premium return by April 30, distribute updated Wage Notices to current employees, run handbook updates for the year.
Q2 (April through June): review job postings for pay transparency compliance, conduct mid-year audit of ESST balances and frontload elections, refresh anti-harassment training under the post-2023 MHRA standard.
Q3 (July through September): apply July 1 minimum wage rates for small and micro employers, recalibrate youth and training wage to 85% of the city rate rounded to the nearest nickel, audit independent contractor classifications.
Q4 (October through December): finalize Q4 Paid Leave premium returns, prepare for January 1 wage rate updates, run end-of-year ESST payout decisions for employers using the payout option, distribute year-end wage notices.

What Annual Trainings Are Recommended?

Annual anti-harassment, anti-discrimination, and anti-retaliation training is not mandated by Saint Paul or Minnesota statute, but it is the most cost-effective protective measure available. Manager training should cover the post-2023 MHRA harassment standard, the ESST harassment expansion, the Wage Theft Ordinance retaliation protections, and the federal NLRA protections for concerted activity. Frontline employee training should cover where to report concerns and what protections apply.

Practical Saint Paul Compliance Workflows

Saint Paul HR teams rarely fail because they don't know the rules. They fail because handoffs between intake, investigation, payroll, and counsel break down. Three workflows tend to cause the most issues in audits and complaints.

How Should a Saint Paul ESST Request Move Through the Organization?

A clean ESST workflow has five steps. Treat each step as a checkpoint, not a formality.

Receive the request: capture the request through whatever channel the employee used and convert it into a single record. Do not require employees to disclose the underlying medical or safety reason.
Confirm coverage: verify the employee has worked at least 80 hours in Saint Paul during the year. If yes, the city ordinance applies. If the employee also works elsewhere in Minnesota, state ESST coverage may also apply.
Apply the time: deduct the requested hours from the accrued or frontloaded balance. Honor the 15-minute increment minimum and the four-hour cap on what the employer can require an employee to use at once.
Documentation only after two days: if the absence stretches beyond two consecutive scheduled workdays, the employer can request reasonable documentation. Limit the request to confirmation of a covered reason, not the underlying details.
Pay through the regular cycle: include ESST in the next regular paycheck and reflect it on the wage statement.

How Should an HREEO Wage Theft Inquiry Be Handled?

If HREEO opens an investigation, the response window is short and the documentation request is broad. Saint Paul employers should be prepared to produce time and pay records, the Employee Wage Notice acknowledgments, ESST records, tip pool records, and any deduction authorizations within the time HREEO sets in the request. The investigator typically opens with a request for documents, follows with employee interviews, and then attempts conciliation. A fast, complete document production substantially reduces the chance of an adverse finding.

How Should Harassment Complaints Be Triaged Under the New MHRA Standard?

Minnesota's 2023 MHRA amendments removed the "severe or pervasive" gating threshold. The practical implication: Saint Paul HR teams cannot dismiss harassment reports because the conduct was a single incident or did not meet a federal threshold. Every complaint should move through intake, investigation, finding, and remediation, with documentation at each stage. The investigator should evaluate whether the conduct was based on a protected class and had the purpose or effect of substantially interfering with employment, regardless of whether it was severe or pervasive.

Investigations and Documentation Best Practices

The 2023 MHRA standard, the new Wage Theft Ordinance, and the ESST harassment expansion all push Saint Paul employers toward more thorough investigations.

What Should the Investigation Plan Cover?

Scope statement: a written description of the allegations and the issues to investigate.
Witness list: identification of complainants, respondents, and corroborating witnesses.
Evidence list: emails, messaging records, schedules, time records, video, and other materials to review.
Timeline: target completion dates for each phase.
Confidentiality plan: who can know what, with documented restrictions.

What Should an Investigation File Look Like?

Each investigation should produce a stand-alone file separate from the personnel records of the parties involved. The file should contain the complaint as received, witness statements with date and signature, evidence reviewed, the investigator's analysis, and the finding. Outcomes should reference specific facts and the city or state standard applied. A well-organized file is the single best protection an employer has if a claim later escalates to HREEO, the Minnesota Department of Human Rights, or court. Many employers use a structured workplace investigations process to keep the documentation chain consistent across cases.

How Long Should Investigation Records Be Kept?

Saint Paul does not set a single retention rule for investigation files. Best practice is to retain investigation records for at least the longest applicable statute of limitations, which is six years for Minnesota Whistleblower Act claims. Many employers default to seven years to provide a buffer. Records should be stored in a controlled-access system with version history, not in personal email or file shares.

Federal Employment Laws That Apply in Saint Paul

Saint Paul employers also fall under the full federal employment law framework. The federal floors interact with Minnesota and city protections in ways that shape day-to-day compliance.

Which Federal Laws Are Most Active for Saint Paul HR?

Title VII of the Civil Rights Act of 1964: prohibits discrimination on the basis of race, color, religion, sex (including pregnancy, sexual orientation, and gender identity under Bostock), and national origin. Covers employers with 15 or more employees.
Americans with Disabilities Act (ADA): prohibits disability discrimination and requires reasonable accommodations for employers with 15 or more employees.
Age Discrimination in Employment Act (ADEA): protects workers 40 and older at employers with 20 or more employees.
Pregnant Workers Fairness Act (PWFA): requires reasonable accommodations for pregnancy, childbirth, and related conditions, effective June 27, 2023.
Family and Medical Leave Act (FMLA): 12 weeks of unpaid, job-protected leave at employers with 50 or more employees within 75 miles of the worksite.
Fair Labor Standards Act (FLSA): federal minimum wage, overtime at one-and-a-half times the regular rate for hours over 40 in a workweek, and child labor restrictions.
National Labor Relations Act (NLRA): protects concerted activity and union organizing for most private-sector employers.
Occupational Safety and Health Act: federal floor for workplace safety, with Minnesota OSHA enforcing state-plan obligations.
Equal Pay Act: prohibits sex-based pay disparities for substantially equal work.
Genetic Information Nondiscrimination Act (GINA): prohibits use of genetic information in employment decisions.
Uniformed Services Employment and Reemployment Rights Act (USERRA): reemployment and protection from discrimination for service members.

How Does Federal Overtime Interact With Minnesota Overtime?

Minnesota overtime under Minn. Stat. § 177.25 requires time and one-half for hours over 48 in a workweek for workers covered by the Minnesota Fair Labor Standards Act. Federal FLSA overtime applies at hours over 40 for FLSA-covered employees. Most employers covered by both standards must pay overtime starting at 40 hours under the FLSA, since the federal rule is more generous and federal coverage typically applies. Saint Paul employers should default to the 40-hour threshold and document any narrow circumstances where state-only coverage applies.

Minnesota Whistleblower Protections

The Minnesota Whistleblower Act, codified at Minn. Stat. § 181.932, gives employees a private right of action when they are disciplined or retaliated against for reporting suspected violations of law. The Act applies broadly to public and private employers in Saint Paul.

What Conduct Is Protected Under the Whistleblower Act?

The Act protects an employee who, in good faith, reports a violation, suspected violation, or planned violation of any federal, state, or common law to an employer or to a government body or law enforcement official. Internal reports to supervisors are protected just like external reports to government agencies. The employee does not need to be correct about the violation. Good-faith belief is sufficient.

What Damages Are Available?

Employees who prevail in a whistleblower retaliation suit can recover lost wages, lost benefits, reinstatement, attorneys' fees, and other equitable relief. The Act has a six-year statute of limitations, longer than most employment claims. Saint Paul employers should treat any internal report of suspected illegality, including wage violations, safety hazards, harassment, or environmental issues, as protected activity. Establishing a structured anonymous reporting channel reduces the risk that employees who later file a whistleblower claim can argue they had no internal mechanism to use.

Minnesota Workforce Privacy and Social Media Rules

Minnesota has specific employee privacy protections that apply in Saint Paul. Three are particularly relevant.

What Are Minnesota's Off-Duty Conduct Protections?

Under Minn. Stat. § 181.938, employers cannot discipline an employee for using lawful consumable products off the employer's premises during nonworking hours. Lawful consumables now include alcohol, tobacco, and adult-use cannabis (legal in Minnesota since August 1, 2023). Exceptions exist for bona fide occupational requirements, federal funding requirements, and certain safety-sensitive positions.

Are Social Media Account Requests Restricted?

Minnesota does not have a comprehensive social media password protection law of the type adopted by some states, but Saint Paul employers should follow the federal NLRA framework that protects concerted social media activity by employees discussing terms of employment. Disciplinary action based on a private social media post about wages, working conditions, or organizing activity is high-risk under federal law.

What Personnel File Access Rules Apply?

Under Minn. Stat. § 181.961, employees can review their personnel records once per six-month period during employment and once per year after separation. The employer must produce records within seven working days of a written request (or 14 days if the records are stored more than 200 miles from the work location). Employees can submit a written rebuttal of disputed information that becomes part of the file.

How AllVoices Helps Saint Paul HR Teams

Saint Paul's compliance regime is dense: ESST documentation rules, Wage Theft Ordinance investigations, Chapter 183 discrimination claims, harassment complaints under the post-2023 MHRA standard, and Paid Leave coordination. Most of the failures we see are not because employers don't know the rules. They are because intake, investigation, and follow-through fall through the cracks across HR, legal, and operations.

AllVoices is an employee relations platform built for this exact problem. The platform gives Saint Paul HR teams a single place to handle:

Anonymous and named intake: employees can raise ESST, harassment, discrimination, or wage concerns through web, mobile, hotline, or QR code, with full anonymity options.
Case management: HR runs every report through the same intake, triage, investigation, and resolution workflow with version-controlled notes.
Vera AI: the AllVoices AI agent handles initial intake conversations and identifies patterns across reports, often surfacing harassment or wage concerns that single complaints would have missed.
Compliance documentation: the platform produces investigation timelines, witness lists, evidence trails, and outcome summaries that align with HREEO documentation expectations.
HRIS integration: the platform connects directly with Workday, Rippling, Paylocity, and other HRIS systems so case data stays synced with employment records.

For a Saint Paul employer juggling ESST tracking, Wage Theft Ordinance complaints, and harassment investigations against the new MHRA standard, the question is whether the employer can produce a clean documentation trail when HREEO calls. Schedule a walkthrough of the AllVoices platform if your team is moving from spreadsheets and email threads to a structured workflow.

Frequently Asked Questions

What is the Saint Paul minimum wage in 2026?

Macro and large employers (101 or more employees) must pay $16.37 per hour effective January 1, 2026. Small employers (6-100 employees) pay $15.00 from July 1, 2025, increasing to $16.37 on July 1, 2026. Micro employers (5 or fewer) pay $13.25 from July 1, 2025, increasing to $14.25 on July 1, 2026.

When did Saint Paul's Wage Theft Ordinance take effect?

The Saint Paul Wage Theft Ordinance took effect January 1, 2025. The ordinance gives the HREEO Labor Standards Division authority to investigate wage theft claims and to require employers to provide an Employee Wage Notice at the start of employment.

Does Saint Paul ESST cover harassment?

Yes. After the November 16, 2025 amendments, harassment is a standalone qualifying use of safe time under Saint Paul ESST. State ESST does not include harassment as a separate use, so employers must apply the city standard for Saint Paul employees.

When can a Saint Paul employer require documentation for an ESST absence?

Employers may request reasonable documentation only after the employee is absent for more than two consecutive scheduled workdays. The previous threshold was three consecutive days; the change took effect November 16, 2025.

What is the 2026 Minnesota Paid Leave premium?

The combined 2026 premium is 0.88% of wages up to $185,000, allocated as 0.61% medical leave and 0.27% family leave. Small employers can pay a reduced 0.66% rate. Employers must pay at least 50% of the premium and may deduct the remainder from employee wages.

Does Minnesota's pay transparency law cover Saint Paul employers?

Yes. Employers with 30 or more employees in Minnesota must include a salary range, a general description of benefits, and other compensation details in any job posting, electronic or print, internal or external, including postings on third-party job boards. The law took effect January 1, 2025.

Can Saint Paul employers test job applicants for cannabis?

Generally no. Pre-employment cannabis testing is prohibited except for safety-sensitive positions, peace officers, firefighters, federally regulated transportation workers, and certain healthcare positions. Reasonable suspicion testing remains available with DATWA-compliant policies.

What is the Minnesota workplace harassment standard?

Minnesota's MHRA does not require harassment to be "severe or pervasive" to be actionable. The legislature amended the Act in 2023 to clarify that conduct does not need to meet that threshold. Conduct must be based on a protected class and have the purpose or effect of substantially interfering with employment or creating a hostile environment.

Does Minnesota allow non-compete agreements?

No, with two narrow exceptions. Minn. Stat. § 181.988, effective July 1, 2023, bans most post-employment non-competes. Carveouts apply to agreements connected to the sale or dissolution of a business. Confidentiality, trade secret, and non-solicitation agreements remain permitted.

The Bottom Line

Saint Paul HR teams have more compliance surface area than most cities of comparable size. The city Minimum Wage Ordinance, ESST Ordinance with the November 2025 amendments, Wage Theft Ordinance with HREEO enforcement, and Chapter 183 discrimination protections sit on top of an active state framework that includes Minnesota Paid Leave (effective January 1, 2026), the post-2023 MHRA harassment standard, the CROWN Act, and pay transparency obligations. The 2026 priorities for Saint Paul HR teams:

By April 30, 2026: file the first quarterly Minnesota Paid Leave premium return and confirm payroll withholding is accurate.
By July 1, 2026: apply the new $16.37 small-employer minimum wage and the $14.25 micro rate for any Saint Paul work.
Throughout 2026: retrain managers on the harassment-as-standalone-ESST use and the two-day documentation rule from the November 2025 amendments.
Ongoing: maintain wage notice acknowledgments, time and pay records, ESST records, and investigation documentation per the three-year retention rule, and run all complaint intake through a documented case management workflow.

For HR teams ready to centralize Saint Paul intake and investigations, see how the AllVoices platform handles employee relations end to end.