Now Is the Time to Plan Your 2027 Employee Handbook Updates
The end of the year has a way of arriving quickly. For employers, now is a good time to begin reviewing employee handbooks and workplace policies for necessary changes in 2027.
Several new and recently enacted employment laws are taking effect next year. For multi-state employers in particular, the growing patchwork of state and local requirements can make handbook maintenance increasingly complex. Waiting until December to begin the review can leave HR teams scrambling to determine which laws apply, and how to revise policies, obtain necessary approvals, and communicate changes.
Employers do not need to finalize their 2027 handbooks today, particularly because some legislative and regulatory developments are still evolving. What employers can do is begin identifying the policies that require attention and the state or local supplements that may need to be revised. The changes an employer must address will depend on where employees work, the employer’s size, and the nature of its workforce. As employers prepare for 2027, several areas are particularly worth examining.
Leave and Time-Off Policies
Paid sick leave, paid family and medical leave, military leave, jury duty, and other protected absences continue to be active areas of state legislation. For example, employers may encounter changes involving:
- Expansion of paid sick leave to additional employers or employees
- New or expanded family and medical leave programs
- Paid jury-duty requirements
- Protections for military members and their spouses
- Leave associated with childbirth, postpartum care, or children’s medical appointment
- Protections for volunteer emergency responders
Employers should compare existing handbook provisions against the requirements in every jurisdiction where employees work. Specific attention should be paid to eligibility, permissible reasons for leave, whether leave is paid or unpaid, notice requirements, use of PTO, continuation of benefits, job restoration, and anti-retaliation protections.
Wage-and-Hour Policies
Minimum wage changes remain a familiar New Year’s compliance issue, but the review should extend beyond statewide minimum wage rates. Depending on the jurisdiction and workforce, 2027 developments may affect local minimum wage rates, tipped wages, agricultural overtime, exempt salary thresholds, meal and rest periods, and payroll practices.
Handbooks that state specific dollar amounts can become outdated quickly. Employers may want to consider whether policies should instead reference the applicable federal, state, or local minimum wage, with the actual rate communicated through required postings or other employee notices.
Pay Transparency and Recruiting Practices
Pay transparency requirements continue to expand at the state and local levels, with new laws potentially requiring employers to disclose salary or wage ranges, benefits, or other compensation information in job postings. These requirements often affect more than the employee handbook. Employers should review:
- Job-posting templates
- Internal promotion postings
- Compensation ranges
- Benefits descriptions
- Applicant-tracking systems
- Recruiter and hiring-manager practices
Multi-state employers should also pay close attention to remote positions because the applicable disclosure requirements may depend on where the employee could work, not simply where the employee is headquartered.
Reasonable Accommodation and Equal Employment Opportunity Policies
Reasonable accommodation obligations are also evolving. New requirements may expand protections for certain medical conditions or require employers to provide employees with additional information about their accommodation rights. For example, new requirements may affect policies concerning disabilities, pregnancy and related conditions, lactation, and menopause-related conditions.
Employers should consider reviewing EEO and accommodation policies together rather than treating each as an isolated update. The goal should be to ensure employees understand how to request an accommodation and that managers know where to direct those requests.
Artificial Intelligence in Employment Decisions
As employers increasingly incorporate artificial intelligence and automated tools into recruiting and other employment processes, regulation of those tools is expanding as well. Depending on the jurisdiction and technology involved, an employer may face requirements concerning notice, use of employee or applicant data, adverse employment decisions, human review, recordkeeping, or other safeguards.
The handbook review also provides an opportunity to ask a broader question: Where is the organization actually using AI in its employment processes? The answer may involve more than recruiting. AI-enabled tools can appear in compensation, performance management, promotion, scheduling, discipline, or other HR processes. Employers should consider inventorying these tools and determining whether a standalone AI policy, an employee notice, or internal HR procedures are appropriate.
Restrictive Covenants and Repayment Agreements
Restrictions involving noncompetes, nonsolicitation agreements, training repayment provisions, tuition assistance, sign-on bonuses, relocation assistance, and other “stay-or-pay” arrangements continue to receive legislative attention.
Although these provisions do not belong in the employee handbook, the annual handbook review is a good reminder to examine related documents at the same time, including offer-letter templates, employment agreements, restrictive covenant agreements, tuition policies, bonus agreements, and relocation agreements.
A Practical Approach to the 2027 Review
A practical 2027 review can begin with the following steps:
- Identify every jurisdiction in which employees actually work, including remote employees
- Compare applicable 2027 requirements against existing policies
- Separate true handbook changes from operational compliance items, such as payroll, posters, job postings, or recordkeeping
- Review state and local supplements rather than assuming a national policy can address every requirement
- Audit related documents, including offer letters, restrictive covenant agreements, leave forms, accommodation procedures, and recruiting templates
- Train HR personnel and managers where a legal change affects day-to-day decision-making
- Plan for a final year-end check, particularly in jurisdictions where legislation, agency guidance, wage rates, or regulations remain pending
An employee handbook should reflect how an organization operates, not merely summarize employment laws. The annual review offers an opportunity to do more than just insert new statutory language. Employers can use the 2027 review to identify policies that have become outdated, inconsistent across jurisdictions, or disconnected from actual HR practices. Starting that process now provides time to determine what must change, what should change, and what belongs somewhere other than the handbook.
With additional legislative and regulatory developments still possible before 2027, employers should continue monitoring the jurisdictions in which they operate and conduct a final compliance review before updated policies take effect. For help with reviewing employment documents, reach out to Levin Ginsburg’s Employment Law practice group.
