Pennsylvania · Updated May 2026

Pennsylvania labor law, encoded as policies you can deploy.

Federal $7.25 floor — state preemption blocks city wage ordinances for over a decade. PA House passed HB 1549 in June 2025 (102-101) to raise to $15 in Philadelphia and tier by county; bill stalled in Senate Labor & Industry Committee. No 2026 enactment expected. Pennsylvania remains the largest US state on the federal floor.

Last updated: May 4, 2026 22 policies covered Reviewed against PA L&I Bureau of Labor Law Compliance 2026 guidance
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Active

Federal $7.25 Floor Enforcement

Enforces $7.25 federal minimum wage statewide. State preemption blocks city ordinances. Tracks HB 1549 transition planning if Senate enacts the tiered $15 raise.

Block close without vacation payout Surface PLAWA-vacation comingling risk
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Tipped Wage + Tip Makeup

Validates $2.83 cash for tipped workers + tip makeup to $7.25. $135/month tip threshold for tipped classification.

PLAWA balance on every paystub Warn on retaliation pattern
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PMWA Weekly Overtime + 3-Year SOL

Enforces 1.5× past 40 hours under PMWA § 333.104. Full 1.5× for non-exempt salaried workers (Chevalier rejection of fluctuating workweek). 3-year statute of limitations exposure.

Block schedule under 14-day notice Predictability pay on changes

Compliance, on autopilot.

Pennsylvania's wage and hour rules in 2026 are shaped by three structural features: state wage preemption that holds the floor at the federal $7.25 (with HB 1549's tiered $15 raise stalled in the Senate); WPCL individual liability for officers and agents on unpaid wages; and the PMWA's worker-favorable interpretations — including the rejection of the fluctuating workweek method and a 3-year statute of limitations. Layered on top: three local PSL ordinances (Philadelphia, Pittsburgh, Allegheny County) operating without state coordination, healthcare's Act 102 mandatory OT refusal right, Philadelphia Fair Workweek for retail/food/hospitality, and no state PFML or PSL framework. Teambridge encodes all 20 of these as composable rules, runs them at shift create / save / clock-out, and preserves the audit trail.

Optimize
Silently routes around the issue.
Flag
Surfaces a note. Action proceeds.
Avoid
Warns and discourages. Allows override.
Critical
Strong warning. Requires acknowledgment.
Block
Hard stop. Cannot proceed.
Softer Harder
The Pennsylvania policy library

20 rules. The right severity for each.

Pennsylvania's wage and hour rules in 2026 are shaped by three structural features: state wage preemption that holds the floor at the federal $7.25 (with HB 1549's tiered $15 raise stalled in the Senate); WPCL individual liability for officers and agents on unpaid wages; and the PMWA's worker-favorable interpretations — including the rejection of the fluctuating workweek method and a 3-year statute of limitations. Layered on top: three local PSL ordinances (Philadelphia, Pittsburgh, Allegheny County) operating without state coordination, healthcare's Act 102 mandatory OT refusal right, Philadelphia Fair Workweek for retail/food/hospitality, and no state PFML or PSL framework. Teambridge encodes all 20 of these as composable rules, runs them at shift create / save / clock-out, and preserves the audit trail.

Active

Federal $7.25 Floor Enforcement

Enforces $7.25 federal minimum wage statewide. State preemption blocks city ordinances. Tracks HB 1549 transition planning if Senate enacts the tiered $15 raise.

Block save below $7.25 Flag · HB 1549 tiered raise tracking
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Tipped Wage + Tip Makeup

Validates $2.83 cash for tipped workers + tip makeup to $7.25. $135/month tip threshold for tipped classification.

Block tip credit when monthly tips below $135 threshold Flag · weekly tip total tracked
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PMWA Weekly Overtime + 3-Year SOL

Enforces 1.5× past 40 hours under PMWA § 333.104. Full 1.5× for non-exempt salaried workers (Chevalier rejection of fluctuating workweek). 3-year statute of limitations exposure.

Block save without OT premium past 40 Avoid · fluctuating workweek half-time method Critical · 3-year SOL expands back-OT exposure
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FLSA Exempt + Duties Test

Validates exempt classification against $684/week salary basis and federal duties test. Annual review enforced. Misclassification triggers WPCL exposure.

Avoid · classification under salary basis Critical · misclassification + WPCL personal liability
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Healthcare Act 102 OT Refusal Right

Tracks healthcare worker OT refusal right under Act 102. Validates 'unforeseeable emergent circumstances' before mandatory OT. Surfaces retaliation exposure.

Block mandatory OT past scheduled shift Flag · 'unforeseeable emergent circumstances' justification required Critical · retaliation exposure
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Healthcare 8-and-80 OT Calculation

Enables Act 109's 14-day, 80-hour work period for hospitals. OT calculated at hours past 8/day or 80/14-day period.

Flag · 14-day work period election
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Three-Jurisdiction PSL Routing

Routes PSL accrual by location: Philadelphia (1:40, 40hr cap, 10+ employees), Pittsburgh (1:30 in 2026, 72/48hr caps), Allegheny County (1:35, 40hr cap, 26+ employees). Per-shift, parcel-level routing.

Block payroll without PSL accrual for in-jurisdiction work Flag · Pittsburgh 2026 expansion (1:30 + raised caps) Avoid · jurisdiction misrouting
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Philadelphia Fair Workweek

Enforces 14-day advance schedule notice for retail/food/hospitality at 250+ global or 30+ location employers. Generates predictability pay for changes.

Block schedule changes within 14 days without predictability pay Flag · 9-hour minimum gap between shifts Critical · right to refuse non-employer-initiated changes
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WPCL Individual Liability Tracking

Surfaces individual exposure for officers, agents, HR leaders on wage payment decisions. 25% liquidated damages or $500 minimum + attorney fees on violations.

Flag · individual liability scope Critical · 25% liquidated damages + criminal exposure
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Next-Payday Final Pay (Both Discharge and Quit)

Queues final pay for next regular payday following last day. Same rule for discharges and voluntary quits under WPCL § 260.5. Includes wages, OT, commissions, vacation per policy.

Block separation save without next-payday final pay queued Critical · WPCL individual liability for late pay
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Vacation Per Policy

Routes vacation payout per employer's written policy. Tracks consistency of application. Once committed, late = WPCL exposure.

Flag · vacation per written policy Avoid · inconsistent forfeiture application
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Wage Statement + 3-Year Records

Generates compliant per-paystub statements per WPCL § 260.4. Maintains 3-year wage records. Records support good-faith defense on wage claims.

Block payroll without compliant wage statement Flag · 3-year records retention
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Two-Track IC Test (Common-Law + Act 72 ABC)

Common-law multi-factor test for most industries. Three-prong ABC test under Act 72 for construction. Validates each engagement against the applicable framework.

Avoid · IC engagement failing applicable test Critical · misclassification + Act 72 civil/criminal exposure
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Minor Employment Rules

Validates minor age and working papers at hire. Enforces hour caps and time-of-day restrictions. Blocks hazardous occupation assignments under federal HOs.

Block schedule violating minor hour caps Block hazardous occupation assignment Flag · working papers required for hire
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Multi-Local PSL Coordination

When workers route across Philadelphia, Pittsburgh, and Allegheny County in same week, system tracks separate accrual buckets per jurisdiction.

Flag · multi-jurisdiction balance maintenance
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Pay Frequency + Timing

Enforces semimonthly minimum pay frequency under WPCL § 260.3. End-of-pay-period to payday gap limited.

Block payroll exceeding semimonthly cadence
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Wage Deduction Authorization

Routes wage deductions per § 260.3. Required-by-law deductions automatic. Other deductions require written authorization on PA L&I-approved form.

Block deduction without written authorization Avoid · deductions for unreturned property without auth
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Anti-Retaliation Surveillance

Surfaces adverse actions correlated with wage complaints, PSL use, Act 102 OT refusals, Fair Workweek change refusals. Schedule changes within retaliation windows flagged.

Flag · adverse actions correlated with protected activity Critical · retaliation = separate civil exposure
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FMLA + Local PSL Coordination

Coordinates federal FMLA (50+ employees, 12 weeks unpaid) with local PSL accrual for paid coverage during qualifying leave. No state PFML.

Flag · federal FMLA + local PSL coordination
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Construction Act 72 ABC Test

Strict three-prong validation for construction IC engagements. Written contract + free from control + customarily engaged in independent trade. All three required.

Block construction IC engagement failing any Act 72 prong Critical · misclassification + Act 72 criminal exposure
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01$7.25 statewide, no city ordinances permitted, HB 1549 tiered raise stalled

Pennsylvania's minimum wage is $7.25/hr — the federal floor under the Fair Labor Standards Act, unchanged since July 24, 2009. The state's Minimum Wage Act of 1968 (43 P.S. §§ 333.101-333.115) adopts the federal rate by reference. Pennsylvania has not legislated any state-specific increase above federal in over 16 years.

State law preempts local minimum wage ordinances. Pennsylvania's preemption statute (passed 2006 alongside the last state minimum wage increase) prohibits cities and counties from setting higher minimum wages. Philadelphia, Pittsburgh, Lancaster, and Allentown have passed resolutions supporting preemption repeal; bills like SB 19 (2025) and HB 1150 have been introduced but have not advanced. Until preemption is repealed, no local minimum wages are permitted.

House Bill 1549 — passed the PA House on June 11, 2025 by a 102-101 vote — would amend the Pennsylvania Minimum Wage Act to introduce a tiered minimum wage by county population. Key provisions: Philadelphia (1st class county): $15.00/hr beginning January 1, 2026. Next 16 most populous counties (including Allegheny): $12.00/hr in 2026, rising to $15.00 by 2028. Remaining 47 counties: $10.00/hr in 2026, rising to $12.00 by 2028. Annual cost-of-living adjustments for all counties starting January 1, 2029. As of February 2026, the bill has been referred to the Senate Labor and Industry Committee and has not been enacted.

Tipped wage in Pennsylvania: $2.83/hr cash for tipped workers, with employer required to ensure tips bring total compensation to at least $7.25. The tip credit is one of the deeper differentials in the country at $4.42 — reflecting the very low cash wage. Tipped workers must receive at least $135 per month in tips to qualify; below that threshold, the worker is treated as non-tipped and earns the full $7.25 in cash.

The minimum wage is operationally simple in Pennsylvania — a single statewide rate, no city ordinances, no automatic indexing. The complexity instead lives in the OT and exempt frameworks (PMWA's 3-year SOL, fluctuating workweek prohibition) and in the local PSL ordinances (Philadelphia, Pittsburgh, Allegheny County) operating without state coordination.

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Federal $7.25 Floor Enforcement

Enforces $7.25 federal minimum wage statewide. State preemption blocks city ordinances. Tracks HB 1549 transition planning if Senate enacts the tiered $15 raise.

Block save below $7.25 Flag · HB 1549 tiered raise tracking
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Why state wage preemption shapes PA's wage compliance posture Pennsylvania is the largest US state still at the federal $7.25 floor, and the state's preemption statute prohibits cities from enacting higher local minimum wages — a structural posture rare among populous states. Philadelphia, Pittsburgh, Lancaster, and Allentown have passed resolutions supporting preemption repeal, but bills have not advanced. HB 1549's tiered raise (passed PA House 102-101 in June 2025) would have introduced county-population-based minimums starting January 1, 2026 — but the bill remains in the Senate Labor & Industry Committee with no signs of imminent floor action. As of February 2026, the federal $7.25 remains the operative rate. The preemption shapes operational planning: multi-state operators don't need to track separate Philadelphia or Pittsburgh wage ordinances (only PSL ordinances). The downside: Pennsylvania workers in high-cost cities earn substantially less in cash wage than nearby states (CT $16.94, NJ $15.49, NY $16.50 / NYC $17.00), generating significant cross-border wage migration in border counties.

Read the full Pennsylvania federal floor and state wage preemption guide →

02Personal exposure for owners, executives, and HR leaders on unpaid wages

Pennsylvania's Wage Payment and Collection Law (WPCL, 43 P.S. § 260.1 et seq.) governs the timing and methods of wage payment in Pennsylvania. The statute applies to all employers regardless of size and covers all wages, commissions, fringe benefits, and wage supplements. Wages must be paid on regularly designated paydays, with the time between the end of a pay period and payday limited by statute or industry custom.

The distinctive feature: WPCL § 260.9a imposes individual liability on officers, agents, and other persons actively involved in nonpayment. The Pennsylvania Supreme Court has held that liability extends to corporate officers who actively participate in wage payment decisions — meaning owners, executives, HR leaders, and payroll managers can face personal exposure beyond the corporate veil. Mark v. Newport News Industrial Corp. and Carpenters Health & Welfare Fund v. Mgmt. Resource Sys. have affirmed broad reach.

Damages structure: full back wages, plus 25% liquidated damages or $500 minimum (whichever is greater), plus mandatory attorney fees and court costs. The 25% liquidated damages is calculated on the unpaid amount — for a $50,000 wage claim, the liquidated damages are $12,500. Attorney fees can substantially exceed the underlying wage shortfall in litigated cases.

Criminal exposure under § 260.10: willful violations are a summary offense for first violations and a misdemeanor for subsequent violations. While criminal prosecution is rare, the criminal statute creates leverage in civil enforcement and can be invoked in egregious cases. The PA L&I and PA Attorney General's Office have civil enforcement authority but criminal cases proceed through county prosecutors.

WPCL's reach extends beyond regular wages: commissions actually earned per the commission agreement; fringe benefits and wage supplements per employer policy; vacation payout per policy or practice; expense reimbursements; and any other amounts owed. The breadth means most wage-related disputes — including disputes over commission timing, vacation payout, or expense reimbursement — can be brought as WPCL claims with personal liability and liquidated damages exposure.

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WPCL Individual Liability Tracking

Surfaces individual exposure for officers, agents, HR leaders on wage payment decisions. 25% liquidated damages or $500 minimum + attorney fees on violations.

Flag · individual liability scope Critical · 25% liquidated damages + criminal exposure
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Why WPCL personal liability shapes wage compliance strategy Most state wage statutes hold the employer entity liable for unpaid wages. Pennsylvania's Wage Payment and Collection Law (WPCL, 43 P.S. § 260.9a) goes further: officers, agents, and any other person actively involved in the wage payment decisions can be held individually liable. Personal liability extends to owners, executives, HR leaders, and even payroll managers who knowingly participated in nonpayment. Plus 25% liquidated damages or $500 minimum (whichever greater), plus mandatory attorney fees, plus potential criminal penalties under § 260.10 for willful violations. The personal-liability framework changes the calculus on wage decisions. Acquiring an entity with WPCL exposure exposes the acquirer's officers. Authorizing late wage payments — even with good intentions — can expose individual decisionmakers. Pennsylvania's WPCL is one of the most aggressive personal-liability frameworks in US wage law.

Read the full Pennsylvania wpcl individual liability for officers and agents guide →

03Worker-favorable interpretations expand back-OT exposure beyond federal FLSA

Pennsylvania's overtime law (PMWA, 43 P.S. § 333.104) requires overtime pay at 1.5× regular rate for hours past 40 in a workweek. The state law tracks federal FLSA's 40-hour weekly trigger. Pennsylvania does not impose a daily overtime trigger.

The 3-year statute of limitations is one of PMWA's worker-favorable features. Under federal FLSA, the SOL is 2 years for ordinary violations and 3 years only for willful violations — meaning the worker must prove willfulness to access the third year. Pennsylvania's PMWA gives workers a flat 3-year SOL regardless of willfulness, expanding back-OT exposure on every claim by 50% over federal.

The fluctuating workweek prohibition is the more consequential PMWA feature. Under federal FLSA 29 CFR 778.114, employers can pay non-exempt salaried workers a fixed salary for fluctuating hours and calculate overtime at HALF-time premium for hours over 40 (the salary already covers the straight-time portion). This dramatically reduces effective overtime pay for high-hour weeks. The PA Supreme Court rejected this approach in Chevalier v. General Nutrition Centers (2019), holding that PMWA requires the full 1.5× rate calculation for non-exempt salaried workers.

The Chevalier decision retroactively exposed many fluctuating workweek arrangements. Pennsylvania employers that had been paying half-time for OT under the federal method face full 1.5× recalculation back to the start of the relevant period. Combined with the 3-year SOL, the back-OT exposure can be substantial. The decision is a major reason for the increase in PA wage class action filings since 2019.

Exempt classification follows federal FLSA: $684/week salary basis ($35,568/year) plus duties test under 29 CFR Part 541. The DOL's 2024 attempt to raise the threshold was vacated by the Eastern District of Texas in November 2024, leaving the federal $684 in place. Pennsylvania has no state-specific threshold above federal — but the worker-favorable interpretations of duties tests and the 3-year SOL together make misclassification exposure higher in Pennsylvania than the bare federal floor would suggest.

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PMWA Weekly Overtime + 3-Year SOL

Enforces 1.5× past 40 hours under PMWA § 333.104. Full 1.5× for non-exempt salaried workers (Chevalier rejection of fluctuating workweek). 3-year statute of limitations exposure.

Block save without OT premium past 40 Avoid · fluctuating workweek half-time method Critical · 3-year SOL expands back-OT exposure
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Why PMWA's 3-year SOL and fluctuating workweek prohibition matter Pennsylvania's overtime law (PMWA, 43 P.S. § 333.104) tracks federal FLSA on the 1.5× past 40 hours rule — but Pennsylvania courts have interpreted PMWA more favorably to workers in two ways that expand back-OT exposure. First, PMWA's statute of limitations is 3 years for all overtime claims — regardless of willfulness. Federal FLSA is 2 years (3 only for willful violations). The extra year of exposure on every OT claim materially expands back-pay liability. Second, the PA Supreme Court rejected the federal fluctuating workweek method in Chevalier v. General Nutrition Centers (2019). Under federal FLSA, employers can pay non-exempt salaried workers a fixed salary for fluctuating hours and pay only HALF-time for hours over 40. The PA Supreme Court held this method violates PMWA — non-exempt salaried workers in PA must receive FULL 1.5× rate for hours over 40, not half-time. The decision retroactively exposed many salaried-non-exempt arrangements to substantial back-OT liability.

Read the full Pennsylvania pmwa overtime — 3-year sol, no fluctuating workweek guide →

04Philadelphia, Pittsburgh, Allegheny County run separate PSL — Pittsburgh's 2026 expansion

Pennsylvania has no state PSL law. Statewide proposals — including the Family Care Act (HB 200) and various PSL bills — have been introduced but not enacted. As of March 2026, Pennsylvania has not enacted statewide paid sick leave or a state PFML program. The absence of state coverage means Pennsylvania remains in the minority of populous states without statewide PSL.

Three local jurisdictions have enacted PSL ordinances: Philadelphia (Philadelphia Code § 9-4100) — 40 hours per year, 1 hour per 40 worked, applies to employers with 10+ employees. Pittsburgh (Paid Sick Days Act, Chapter 626) — effective January 1, 2026 amendment: 1 hour per 30 worked (from 1:35), up to 72 hours/year at 15+ employee employers and 48 hours at smaller. Allegheny County (Article XXIV) — 40 hours/year, 1 hour per 35 worked, employers with 26+ employees. Allegheny County does not displace stricter Pittsburgh rules within Pittsburgh.

Per-shift routing is required. The applicable PSL rule depends on where the work is performed, not where the worker resides or where the employer's headquarters is located. A worker performing 4 hours in Philadelphia, 3 hours in Pittsburgh, and 2 hours elsewhere in Allegheny County in a single shift accrues under three different rules with potentially different rates and caps.

Pittsburgh's 2026 amendment introduced significant changes. Accrual rate increased from 1:35 to 1:30 — a ~17% increase. Annual caps increased: 72 hours at 15+ employer (up from 40), 48 hours at smaller (up from 24). Tipped worker pay rate now calculated as the numerical average of three SOC categories: 'bartenders' (35-3011), 'waiters and waitresses' (35-3031), and 'dining room and cafeteria attendants and bartender helpers' (35-9011). Stricter retaliation provisions added — employers must prove non-retaliatory motive for adverse actions taken within 90 days of protected activity.

Coordination with potential state PSL: HB 200 (Family Care Act) would create a state PFML program but does not address PSL. If Pennsylvania enacts statewide PSL, the local ordinances would need to coordinate via most-favorable-rule logic (Philadelphia and Pittsburgh have indicated they would maintain ordinances at higher levels if state passes a floor). Until then, the three-jurisdiction patchwork remains the operational reality.

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Three-Jurisdiction PSL Routing

Routes PSL accrual by location: Philadelphia (1:40, 40hr cap, 10+ employees), Pittsburgh (1:30 in 2026, 72/48hr caps), Allegheny County (1:35, 40hr cap, 26+ employees). Per-shift, parcel-level routing.

Block payroll without PSL accrual for in-jurisdiction work Flag · Pittsburgh 2026 expansion (1:30 + raised caps) Avoid · jurisdiction misrouting
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Why local PSL ordinances create per-shift routing complexity Pennsylvania has no state PSL law. But three local jurisdictions — Philadelphia, Pittsburgh, and Allegheny County — operate separate PSL ordinances with different accrual rates, employer thresholds, and pay-rate calculations. Per-shift routing is required: a worker performing work in Philadelphia accrues under Philadelphia Code § 9-4100 (40 hours/year, 1:40 accrual). Pittsburgh work accrues under the Paid Sick Days Act (1:30 effective Jan 1, 2026, up to 72 hours at 15+ employer or 48 hours at smaller). Allegheny County work outside Pittsburgh accrues under the County ordinance (40 hours, 1:35, 26+ employer threshold). Multi-location PA operators face routing complexity Connecticut and Massachusetts don't impose at PSL: a worker on a route through Philadelphia, Pittsburgh, and surrounding Allegheny County in a single week may accrue under three different rules with three different caps.

Read the full Pennsylvania three local psl ordinances — no state framework guide →

05Hospital and care facility workers can decline mandatory overtime

Pennsylvania's Prohibition of Excessive Overtime in Health Care Act (Act 102, 43 P.S. § 932.1 et seq.) was enacted in 2008 to address concerns about excessive mandatory overtime in healthcare settings. The Act applies to hospitals and other 'health care facilities' and protects 'health care workers' — generally registered nurses, licensed practical nurses, certified nurse assistants, and other direct-care staff.

The core protection: healthcare workers may decline to work mandatory overtime past their regularly scheduled shifts without facing retaliation. Mandatory overtime cannot be required as a condition of continued employment. Employers cannot discharge, discipline, or otherwise retaliate against a worker who declines mandatory OT. The right extends to all hours past the worker's regularly scheduled shift — meaning a worker scheduled for 12 hours can refuse OT past hour 12 even if they have not yet reached the 40-hour weekly OT threshold under PMWA.

The 'unforeseeable emergent circumstances' exception is narrow. Qualifying circumstances include: declared public emergencies (hurricanes, mass casualty events); sudden patient surges (mass admissions from accidents); urgent patient care needs (surgical emergencies, critical patient deterioration). NOT qualifying: routine staffing shortages; predictable shift demands; chronic understaffing patterns; planned surgical overflow; routine call-outs by other staff. The narrowness means hospitals cannot use 'we're short-staffed' as a basis for mandatory OT.

Coordination with PMWA overtime: Act 102 governs whether OT can be required; PMWA governs how OT is paid. Both apply to healthcare work. A worker who voluntarily accepts OT is paid at PMWA's 1.5× rate for hours past 40. A worker who is improperly required to work mandatory OT under Act 102 has separate civil claims for retaliation, in addition to any PMWA underpayment claims.

Penalty structure: Act 102 violations are subject to civil penalties enforceable by the PA Department of Health and the PA Department of Labor & Industry. Workers also have private right of action for retaliation. Pennsylvania's '8 and 80' overtime rule for healthcare (Act 109 amendment to PMWA) operates separately: it allows hospitals to use a 14-day, 80-hour work period instead of the 40-hour weekly trigger for OT calculation. Act 109 governs OT calculation; Act 102 governs OT refusal. Operating both frameworks simultaneously requires precise scheduling and pay calculation.

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Healthcare Act 102 OT Refusal Right

Tracks healthcare worker OT refusal right under Act 102. Validates 'unforeseeable emergent circumstances' before mandatory OT. Surfaces retaliation exposure.

Block mandatory OT past scheduled shift Flag · 'unforeseeable emergent circumstances' justification required Critical · retaliation exposure
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Why Act 102 distinguishes Pennsylvania healthcare from other states Pennsylvania's Prohibition of Excessive Overtime in Health Care Act ('Act 102', 43 P.S. § 932.1 et seq.) gives healthcare workers in hospitals and care facilities the right to refuse mandatory overtime past their regularly scheduled shifts. Most states allow employers to require overtime as a condition of employment. Pennsylvania's healthcare framework reverses this. The exception is narrow: 'unforeseeable emergent circumstances' (mass casualty events, sudden patient surges, declared emergencies). Routine staffing shortages, predictable shift demands, and chronic understaffing do NOT qualify. Workers who decline mandatory OT in the absence of unforeseeable emergent circumstances cannot be retaliated against. The framework reshapes Pennsylvania healthcare scheduling and reduces the operational reliance on mandatory OT that other states permit. Hospitals and care facilities operating in PA need active scheduling and self-scheduling tools to manage staffing without violating Act 102's refusal-right framework.

Read the full Pennsylvania healthcare act 102 — mandatory ot refusal right guide →

0614-day advance schedules for retail, food service, and hospitality at large employers

Philadelphia's Fair Workweek Employment Standards Ordinance (effective April 1, 2020) requires advance schedule notice and predictability pay for service workers at large employers in the city. Covered employers: retail, food service, and hospitality businesses with 250+ employees globally OR 30+ locations. The thresholds capture most national chains and large local operators while exempting small business.

Advance schedule requirement: schedules must be provided at least 14 days in advance. The 14-day window is significantly longer than other predictive scheduling laws (Seattle 14 days, NYC 14 days, Oregon 14 days, San Francisco 14 days). The longer window forces planning that just-in-time scheduling cannot accommodate.

Predictability pay structure: schedule changes after posting trigger compensation. Schedule additions (extra hours): 1 hour at regular rate. Schedule reductions (shortened shifts): half the lost hours at regular rate. Cancelled shifts: half the scheduled hours at regular rate. The predictability pay applies even if the worker accepts the change — meaning operators face cost on every schedule change regardless of worker disposition.

Right to refuse non-employer-initiated changes: workers can decline schedule changes initiated by the employer without retaliation. Worker-initiated changes (swap requests, time-off requests) are not subject to predictability pay. The framework distinguishes employer convenience from worker preference.

Right to rest between shifts: workers cannot be scheduled to work shifts within 9 hours of the end of the previous shift. If they accept such a shift, the employer must pay $40 in addition to regular wages. Right to request schedule changes: workers can request schedule changes (preferred shifts, days off) and employers must engage in interactive process. Penalty structure: civil penalties enforceable by Philadelphia's Office of Worker Protections, plus private right of action with attorney fees.

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Philadelphia Fair Workweek

Enforces 14-day advance schedule notice for retail/food/hospitality at 250+ global or 30+ location employers. Generates predictability pay for changes.

Block schedule changes within 14 days without predictability pay Flag · 9-hour minimum gap between shifts Critical · right to refuse non-employer-initiated changes
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Why Philadelphia Fair Workweek shapes retail and hospitality scheduling Philadelphia's Fair Workweek Employment Standards Ordinance (effective April 1, 2020) requires schedule predictability for service workers at large employers. Covered: retail, food service, and hospitality employers with 250+ employees globally OR 30+ locations. Workers must receive their schedules at least 14 days in advance. Schedule changes after posting trigger 'predictability pay': 1 hour at regular rate for changes that don't increase or decrease hours; full pay for cancelled shifts; partial pay for shortened shifts. Workers also have the right to refuse non-employer-initiated changes without retaliation. The framework reshapes large-retailer and chain-restaurant scheduling in Philadelphia. The 14-day window forces planning that other states' just-in-time scheduling doesn't require. Operators expanding to Philadelphia need scheduling tools that handle the predictability pay calculations and the schedule-change workflow.

Read the full Pennsylvania philadelphia fair workweek — schedule predictability guide →

07Industry-specific ABC test for construction; common-law multi-factor for others

Pennsylvania uses different IC tests for different purposes and industries. For most wage and unemployment compensation purposes, Pennsylvania applies a multi-factor common-law test. Factors include: right of control over how the work is performed; method of payment; worker's investment in tools and equipment; opportunity for profit or loss; permanence of relationship; whether work is part of employer's regular business; skill required; characterization by parties. No single factor is dispositive.

For construction work, the Construction Workplace Misclassification Act (Act 72, 43 P.S. § 933.1 et seq., effective February 10, 2011) imposes a stricter three-prong test. ALL THREE prongs must be satisfied to support IC classification: (A) the individual has a written contract; (B) the individual is free from control or direction in performing the work; AND (C) the individual is customarily engaged in an independently established trade, occupation, profession, or business.

Act 72's three-prong test is structurally similar to Connecticut's, Massachusetts's, and California's ABC tests — though with different specific language. The single-prong-failure rule applies: failure on any one prong defeats IC classification. The Pennsylvania Department of Labor & Industry's Bureau of Labor Law Compliance has built a construction misclassification enforcement practice around Act 72. Construction industry violations are a significant share of misclassification enforcement.

Misclassification creates layered exposure: WPCL wage theft (full back wages, 25% liquidated damages or $500 minimum, attorney fees, plus individual liability for officers/agents); unemployment compensation back-contributions and penalties; workers' compensation premium back-payment plus uninsured exposure for any injuries; tax withholding back-payment (federal and PA state income, FICA, FUTA). Combined exposure on multi-worker classifications can reach 7-figures.

Act 72 also imposes civil penalties on employers found to have intentionally misclassified construction workers: up to $1,000 for first violation, $2,500 for subsequent violations. The PA Office of Attorney General has criminal jurisdiction for willful misclassification under Act 72 — a third-degree misdemeanor for first violation, second-degree for subsequent. Criminal prosecutions are rare but the criminal exposure creates enforcement leverage in civil cases.

Active

Two-Track IC Test (Common-Law + Act 72 ABC)

Common-law multi-factor test for most industries. Three-prong ABC test under Act 72 for construction. Validates each engagement against the applicable framework.

Avoid · IC engagement failing applicable test Critical · misclassification + Act 72 civil/criminal exposure
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Why PA's two-track IC framework matters for construction operators Pennsylvania uses a two-track IC framework: a common-law multi-factor test for most industries, and an ABC-style three-prong test specific to construction under the Construction Workplace Misclassification Act (Act 72, 43 P.S. § 933.1 et seq.). For most workers, the common-law test (right of control, opportunity for profit/loss, investment in equipment, permanence, etc.) gives operators more flexibility than ABC-test states like New Jersey or California. But for construction workers, Act 72's three-prong test mirrors the strict ABC framework: free from control, customarily engaged in independently established trade, AND business of the IC. All three prongs must be satisfied. Construction operators in Pennsylvania face significantly more rigorous IC scrutiny than other industries — and the PA Department of Labor & Industry's Bureau of Labor Law Compliance has built a construction misclassification enforcement practice around Act 72.

Read the full Pennsylvania ic misclassification — construction workplace misclassification act guide →

08Next regular payday — both discharge and quit — under WPCL

Pennsylvania's Wage Payment and Collection Law (43 P.S. § 260.5) requires final wages to be paid on the next regular payday following the worker's last day — applies to both discharges and voluntary quits. The unified rule contrasts with Connecticut's bifurcated framework (next business day for discharge, next payday for quit) and Massachusetts's date-of-discharge rule.

Final pay components: regular wages through the last day; overtime past 40 hours in any partial week; commissions actually earned per the commission agreement; nondiscretionary bonuses earned and not yet paid; expense reimbursements; and any other amounts owed. Vacation payout is per employer policy (no statutory requirement).

WPCL § 260.9a's individual liability framework applies to final pay violations. Officers, agents, and other persons who knowingly participated in nonpayment can face personal exposure. Combined with 25% liquidated damages or $500 minimum, mandatory attorney fees, and potential criminal exposure under § 260.10, late final pay creates substantial personal and entity-level exposure.

Disputed final pay: employers must pay all undisputed wages within the next-payday timeframe. Withholding the entire final paycheck because of a dispute over a portion exposes the employer to liability for the undisputed portion plus 25% liquidated damages. The Pennsylvania Supreme Court has been clear that disputes over a portion don't justify holding the full amount.

Final pay deductions: employers cannot deduct from final wages for unreturned company property, training costs, or shortages without written authorization on a PA L&I-approved form. Lawsuits to recover the value are permitted, but paycheck deductions without authorization create separate WPCL exposure. The personal liability framework means officers and HR leaders authorizing improper deductions face individual exposure, not just entity-level liability.

Active

Next-Payday Final Pay (Both Discharge and Quit)

Queues final pay for next regular payday following last day. Same rule for discharges and voluntary quits under WPCL § 260.5. Includes wages, OT, commissions, vacation per policy.

Block separation save without next-payday final pay queued Critical · WPCL individual liability for late pay
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Why PA's next-payday rule is more permissive than CT or MA Pennsylvania's final pay framework is structurally more permissive than Connecticut (next business day for discharge) or Massachusetts (date of discharge). Under the WPCL (43 P.S. § 260.5), final wages are due on the next regular payday following the worker's last day — for both discharges and voluntary quits. The same-deadline-for-both rule simplifies operations: no bifurcated logic depending on who initiated the separation. But WPCL's individual liability for officers and agents and 25% liquidated damages framework still apply — meaning late final pay generates personal exposure for the executives or HR leaders who authorized or oversaw the late payment. Vacation payout is governed by employer policy (Pennsylvania does not require statutory payout). Once policy commits to payout, late vacation payout triggers WPCL exposure. Officers and agents face personal liability.

Read the full Pennsylvania final pay and termination guide →

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What changed in Pennsylvania for 2026

Pennsylvania's 2026 changes are mostly local: Pittsburgh PSL Phase 2 (Jan 1, 2026) tightened accrual to 1:30 and raised caps to 72 hours (15+) / 48 hours (<15); statewide HB 1549 minimum wage tiered raise stalled in Senate after passing House 102-101 in June 2025; and the cumulative weight of the 2019 fluctuating workweek rejection plus WPCL individual liability continues to drive class action filings.

  • Pittsburgh PSL Phase 2 (Jan 1, 2026) — accrual increased to 1 hour per 30 worked (from per-35), with annual caps raised to 72 hours at 15+ employee employers and 48 hours at smaller. Tipped worker pay rate now calculated as numerical average of 'bartenders', 'waitstaff', and 'dining room attendants' SOC categories. Stricter retaliation provisions added.
  • HB 1549 minimum wage raise (passed House June 2025, stalled in Senate) — would raise PA minimum wage on a tiered basis: $15/hr in Philadelphia (1st class county) effective January 1, 2026; $12 in next 16 counties (rising to $15 by 2028); $10 in remaining 47 counties (rising to $12 by 2028). As of February 2026, in Senate Labor & Industry Committee, not enacted.
  • Federal $7.25 unchanged — Pennsylvania remains the largest US state at the federal floor, with state preemption blocking local wage ordinances. Philadelphia, Pittsburgh, Lancaster, and Allentown have passed resolutions supporting preemption repeal; bills in the legislature have not advanced.
  • 2024 federal exempt salary increase vacated — November 2024 Eastern District of Texas decision vacated DOL's increase to $1,128/week. Federal $684/week remains the controlling exempt threshold. Pennsylvania has no state-specific threshold above federal.
  • One Big Beautiful Bill Act (federal, July 2025) — created federal income tax deduction for qualified overtime compensation under IRC § 225 starting tax year 2025. Affects payroll W-2 reporting in PA but does not change the underlying overtime payment requirement.

Frequently asked questions

What's the Pennsylvania minimum wage in 2026?
$7.25/hr — the federal floor under FLSA, unchanged since July 24, 2009. Pennsylvania remains the largest US state at the federal floor. State wage preemption blocks city wage ordinances. HB 1549 (passed PA House 102-101 in June 2025) would tier minimum wage by county population — Philadelphia $15 in 2026, smaller counties phasing up — but stalled in the Senate Labor & Industry Committee.
Can Pennsylvania cities set higher minimum wages?
No. Pennsylvania's preemption statute prohibits cities and counties from setting higher minimum wages. Philadelphia, Pittsburgh, Lancaster, and Allentown have passed resolutions supporting preemption repeal; bills have been introduced but not advanced. Until preemption is repealed, no local minimum wages are permitted.
What's Pennsylvania's tipped wage?
$2.83/hr cash for tipped workers, with employer required to ensure tips bring total compensation to at least $7.25. Workers must receive at least $135 per month in tips to qualify for tipped wage classification — below that threshold, the worker earns full $7.25 in cash.
What's Pennsylvania's overtime rule?
1.5× regular rate for hours past 40 in a workweek under PMWA (43 P.S. § 333.104). Pennsylvania does not have a daily overtime trigger. PMWA's statute of limitations is 3 years for all OT claims (vs federal FLSA's 2 years for ordinary, 3 for willful). The PA Supreme Court rejected the federal fluctuating workweek method in Chevalier v. General Nutrition Centers (2019) — non-exempt salaried workers must receive full 1.5× rate, no half-time shortcut.
What's the exempt salary threshold in Pennsylvania?
$684/week ($35,568/year) — the federal FLSA threshold under 29 CFR Part 541. Pennsylvania has no state-specific threshold above federal. The DOL's 2024 attempt to raise the threshold was vacated by the Eastern District of Texas in November 2024.
Does Pennsylvania have a state Paid Sick Leave law?
No. Three local jurisdictions have PSL ordinances: Philadelphia (40 hours/year, 1:40 accrual, 10+ employees); Pittsburgh (effective Jan 1, 2026: 1:30 accrual, 72 hours/year at 15+, 48 hours at smaller); Allegheny County (40 hours/year, 1:35, 26+ employees). Per-shift routing is required for multi-jurisdiction operations.
Does Pennsylvania have a state PFML program?
No. The Family Care Act (HB 200) would create a state PFML program but has passed committee in the PA House without enactment. Federal FMLA provides 12 weeks unpaid, job-protected leave at 50+ employee employers (within 75 miles).
What's the WPCL individual liability rule?
Pennsylvania's Wage Payment and Collection Law (43 P.S. § 260.9a) imposes individual liability on officers, agents, and persons actively involved in wage payment decisions. Owners, executives, HR leaders, and payroll managers can face personal exposure for unpaid wages — beyond the corporate entity. Plus 25% liquidated damages or $500 minimum, plus mandatory attorney fees, plus potential criminal exposure for willful violations under § 260.10.
What's Healthcare Act 102?
Pennsylvania's Prohibition of Excessive Overtime in Health Care Act (43 P.S. § 932.1 et seq.) gives healthcare workers in hospitals and care facilities the right to refuse mandatory overtime past their regularly scheduled shifts. Exception: 'unforeseeable emergent circumstances' (mass casualty, sudden patient surges, declared emergencies). Routine staffing shortages don't qualify.
What's the final paycheck rule in Pennsylvania?
Next regular payday following the worker's last day — for both discharges and voluntary quits under WPCL § 260.5. Unified rule (no bifurcation by who initiated). WPCL individual liability and 25% liquidated damages apply to late final pay.
What's the IC test in Pennsylvania?
Two-track framework. Most industries: multi-factor common-law test (right of control, opportunity for profit/loss, etc.). Construction: three-prong ABC-style test under the Construction Workplace Misclassification Act (Act 72, 43 P.S. § 933.1) — written contract, free from control, customarily engaged in independent trade. ALL three required for construction IC.
Does Pennsylvania have predictive scheduling?
Yes — but only in Philadelphia. Philadelphia's Fair Workweek Ordinance requires 14 days advance schedule notice for retail, food service, and hospitality employers with 250+ employees globally or 30+ locations. Schedule changes trigger predictability pay (1 hour for additions, half lost hours for reductions, half scheduled hours for cancellations).

Primary sources

  1. Pennsylvania Minimum Wage Act of 1968 — 43 P.S. §§ 333.101-333.115 (PMWA)
  2. PA Wage Payment and Collection Law — 43 P.S. § 260.1 et seq. (WPCL)
  3. WPCL § 260.9a — Individual Liability for Officers and Agents
  4. WPCL § 260.5 — Final Wages on Termination
  5. WPCL § 260.10 — Criminal Penalties for Willful Violations
  6. PA Prohibition of Excessive Overtime in Health Care Act — 43 P.S. § 932.1 et seq. (Act 102)
  7. PA Construction Workplace Misclassification Act — 43 P.S. § 933.1 et seq. (Act 72)
  8. PMWA Act 109 (2012) — 8-and-80 Healthcare Overtime Rule
  9. 34 Pa. Code Chapter 231 — PMWA Implementing Regulations
  10. Chevalier v. General Nutrition Centers, 215 A.3d 1002 (Pa. 2019) — Fluctuating Workweek Rejection
  11. Philadelphia Code § 9-4100 — Philadelphia Paid Sick Leave
  12. Philadelphia Fair Workweek Employment Standards Ordinance
  13. Pittsburgh Code Chapter 626 — Paid Sick Days Act (amended Jan 1, 2026)
  14. Allegheny County Article XXIV — Paid Sick Leave Ordinance
  15. 29 USC 207 — Federal FLSA Overtime
  16. 29 CFR Part 541 — White-Collar Exemptions ($684/week federal)
  17. 29 CFR 778.114 — Federal Fluctuating Workweek (rejected by PA Supreme Court)
  18. 29 USC 2601 — Federal FMLA
  19. PA L&I Bureau of Labor Law Compliance — Wage and Hour Compliance
  20. HB 1549 (passed PA House June 11, 2025) — Tiered Minimum Wage Bill (stalled in Senate)
  21. HB 200 — Family Care Act (proposed PA PFML, not enacted)
  22. Texas v. DOL (E.D. Tex. Nov 2024) — Vacated 2024 DOL salary basis increase

This guide is for general informational purposes only and is not legal advice. Pennsylvania labor laws change frequently. For advice on your specific situation, consult licensed Pennsylvania employment counsel. Found something out of date? Let us know.