EOR & Compliance Digest, July 24: New York City’s Sick Leave Rules Just Got More Specific

If you have even one employee in New York City, yesterday mattered. NYC protected time off rules under the Earned Safe and Sick Time Act took effect July 23. The city’s rulebook is now far more specific about how you track unpaid leave. Meanwhile, three other deadlines deserve your attention this week. Tennessee rewrote its noncompete law for anyone earning under $70,000. India opened a 60-day registration clock for its new Occupational Safety Code. And Denmark quietly raised the salary floor for work permits. None of these will make headlines outside HR circles. However, all four carry real payroll and legal exposure if you miss them.

NYC Protected Time Off Rules Get Stricter

What Changed

New York City’s Department of Consumer and Worker Protection adopted amended rules on July 23, 2026. They sit under the Earned Safe and Sick Time Act. The update clarifies NYC protected time off, the unpaid leave category next to the city’s existing paid sick leave (National Law Review).

Every employee now gets an extra 32 hours of unpaid protected time off. It applies regardless of company size. It is available immediately at hire, and it refreshes each calendar year. This unpaid bucket sits on top of the paid leave employers already owe. That is 56 hours for companies with 100 or more employees. It is 40 hours for companies with five to 99 employees (Mayer Brown).

Why This Matters for a Distributed Team

For a 30-person startup with a New York office, this is not abstract. Say a new hire starts in August. She needs unpaid leave in week one to help a family member recover from surgery. Under the old rules, that request sat in a gray area. Under the amended rules, she gets up to 32 hours of NYC protected time off starting day one. It doesn’t matter whether she has accrued any paid leave yet. If she has both paid and unpaid protected time off available, you must apply the paid leave first. The exception: she specifically asks for unpaid instead. Get that sequencing wrong, and you have a wage claim, not just an HR headache.

The rule also tightens recordkeeping. Employers must track paid and unpaid protected time off as separate balances. They must also log the specific reason for each use: a sick family member, a public health emergency, or safety measures after domestic violence, stalking, or workplace violence. If your HRIS lumps all sick leave into one bucket, it no longer matches what the city expects on paper.

What to Do About NYC Protected Time Off This Week

First, check whether your payroll or HRIS platform tracks paid and unpaid protected time off separately. One combined “sick leave” line is no longer enough. Second, update your employee handbook before your next new-hire packet goes out. Finally, if you use an EOR or PEO for New York-based staff, ask them directly whether their leave tracking already reflects July 23. Do not assume it does.

Away from New York, three more deadlines are just as easy to miss this week.

Tennessee Voids Noncompetes Below $70,000

Tennessee’s new noncompete law took effect July 1, 2026. It changes the math for anyone hiring in the state. Any noncompete signed, renewed, or amended on or after that date is void below one threshold. If the employee’s total annualized compensation, including wages, bonuses, and commissions, falls under $70,000, the agreement does not hold (National Law Review). Above that line, the law actually flips in the employer’s favor. Restrictions of two years or less are now presumed reasonable, which makes those agreements easier to enforce.

Is action required? Yes, and soon. Existing noncompetes for employees already under $70,000 are not automatically void, since the threshold only hits new or renewed agreements. But any offer letter or amendment sent after July 1 needs legal review first. So what does this mean in practice? If you’re hiring junior or mid-level talent in Tennessee, drop the noncompete clause below that salary line. It will not hold up anyway.

India’s OSH Code Starts a 60-Day Registration Clock

India’s Occupational Safety, Health and Working Conditions Code folds registration into one filing. It covers any establishment with ten or more workers. This replaces the separate registrations that used to apply to factories, contractors, and inter-state migrant workers (India Briefing). Establishments get 60 days from the date the Code applies to them. Miss that window, and a late fee kicks in. Contractors placing 50 or more workers at another company’s site need their own license, valid for five years.

For HR and finance teams managing Indian entities or EOR arrangements, this single-registration model is genuinely good news. But only if you file inside the window. Miss the 60 days, and you pay a penalty for a process built to be simpler, not slower. If your India entity, or your EOR partner’s local entity, hasn’t confirmed OSH Code registration yet, ask this week. Do not wait for next quarter.

Denmark Raises the Work Permit Salary Floor

Denmark updated the income data behind its Pay Limit Scheme. The change applies to any work or residence permit application submitted after June 30, 2026. The ordinary Pay Limit Scheme minimum is now DKK 552,000 a year. The Supplementary Pay Limit Scheme minimum, meanwhile, has actually been lowered to DKK 322,000 (Erickson Immigration Group). Only fixed and guaranteed pay, pension contributions, and holiday allowances count toward that threshold. Housing or meal benefits do not, even if they appear in an offer letter.

The numbers come from Q1 2026 income data. They get refreshed every quarter, so the next adjustment lands October 1. Therefore, if you’re extending an offer to a non-EU hire in Denmark this quarter, confirm the base salary clears the new floor first. Do this before you submit the permit application, not after.

Quick Hits

• New Hampshire’s lactation break law has been in force since July 2025. But civil penalty enforcement only started July 1, 2026: up to $2,500 per violation, assessed once, for employers with six or more employees (Workyard, citing RSA 275:78-83).
• Canada’s IRCC signed a new policy in June 2026. It builds a work-permit-to-permanent-residence bridge that runs through the end of 2032. The actual application pathway, however, will not open until winter 2027 (Government of Canada).

Action Items This Week

If you hire in New York City: Split paid and unpaid protected time off into separate HRIS balances. Confirm new hires can access their 32 unpaid hours starting day one. Review the full breakdown of US leave categories if your handbook still treats sick leave as one bucket.

If you have Tennessee noncompetes: Pull your standard template. Confirm it no longer applies below $70,000 in total compensation for any agreement signed after July 1. Check US employment law requirements by state before you send the next offer letter.

If you run an India entity or work with an India EOR: Confirm OSH Code registration is filed within 60 days of applicability, before the late fee kicks in. Asanify’s guide to hiring in India covers the registration basics for a first-time entity setup.

If you’re hiring in Denmark: Verify the offered base salary, not the total package, clears DKK 552,000. Under the Supplementary scheme, the floor is DKK 322,000. See Denmark hiring requirements for the full process.

Managing contractors in any of these countries? It’s worth revisiting how work permit and visa processes actually work before you extend an offer. Permit timelines rarely match hiring timelines.

Tracking leave balances, noncompete thresholds, and registration deadlines across four regulatory systems by hand is exactly how compliance gaps happen. Asanify’s Global HRMS builds country-specific rules, like NYC’s protected time off split or Denmark’s salary floor, directly into payroll and leave policies. Worth a look if you manage distributed teams across more than one of these countries.

Frequently Asked Questions

Q: What is NYC protected time off, and how is it different from paid sick leave?
A: Protected time off is unpaid leave under NYC’s Earned Safe and Sick Time Act. It sits apart from the paid sick leave employers already provide. Every employee gets 32 hours of it immediately at hire, on top of 40 to 56 hours of paid leave depending on company size.

Q: Does Tennessee’s new noncompete law apply to agreements signed before July 1, 2026?
A: No. The $70,000 threshold only applies to noncompetes entered into, renewed, or amended on or after July 1, 2026. Agreements signed earlier are not automatically voided unless they are later renewed or amended.

Q: Who needs to register under India’s OSH Code, and what is the deadline?
A: Any establishment with ten or more workers must register within 60 days of the date the Code applies to it. Contractors supplying 50 or more contract workers need a separate five-year license.

Q: What counts toward Denmark’s new work permit salary thresholds?
A: Only fixed and guaranteed pay, pension contributions, and holiday allowances count. Housing or meals do not count toward the DKK 552,000 minimum, or the DKK 322,000 floor under the Supplementary Pay Limit Scheme.

Q: How often do these compliance deadlines change?
A: More often than most HR calendars account for. Denmark updates its income thresholds quarterly. US state laws shift every legislative session. A recurring monthly compliance check, per country you hire in, is the only way to avoid missing one.

Not to be considered as tax, legal, financial or HR advice. Regulations change over time so please consult a lawyer, accountant  or Labour Law  expert for specific guidance.