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While 2025 was a fairly quiet year for employment law developments in the Buckeye State, there were several legal developments worth noting. All employers with an Ohio workforce should be aware of and ensure compliance with certain new laws addressed below, and employers in certain locations will need to heed additional new laws applicable only in their places of business.
Ohio's Mini-WARN Act — Ohio Revised Code 4113.31
Most employers are familiar with the federal Worker Adjustment and Retraining Notification (WARN) Act, which, for decades, has required large employers nationwide to follow strict notice requirements for qualified plant closings and mass layoffs. Effective September 29, 2025, Ohio became the thirteenth state to enact its own "Mini-WARN Act." This is a supplement to the federal WARN Act that imposes additional, more detailed requirements for giving notice to employees whose jobs are being eliminated as part of a mass layoff.
This new law applies to the same "employers" already covered under the federal WARN Act. It largely relies upon and mirrors federal law, incorporating the same definitions for "mass layoff" and "plant closings." Ohio law deviates, however, in its omission of the federal requirement that a "mass layoff" constitute at least "33% of the workforce" an employer maintains at a single workplace. While federal law defines a "mass layoff" as one that impacts fifty (50) or more employees if that number represents 33% of the workforce, the Ohio Act specifically omits the "33% of the workforce" language. There is thus an open question as to whether the trigger notice applies even if the layoff of 50 or more employees does not represent 33% of a business's workforce. This omission results in a recognized ambiguity that may be clarified as case law develops over the statute's application to real life scenarios, or potentially by amendment.
Ohio's Mini-WARN Act also requires employers to provide employees with a notice that contains, among other things: (1) the location of the facility or plant affected; (2) a detailed statement explaining the reason for the plant closing or mass layoff and whether it will be permanent or temporary; (3) the expected date the plant closing or mass layoff will occur and the anticipated date on which the employees' employment will cease; (4) the total number of employees affected by the plant closing or mass layoff; and (5) the total number of employees affected by the plant closing or mass layoff, including the employees' job titles or positions and any department or division impacted. The employer must include additional information in the notice if the employees do not have an authorized representative at the time the notice is sent.
The Act also contains certain requirements applicable to unionized workforces and requires certain notices to be provided to government officials. Employers can find more information codified at R.C. 4113.31 as well as in guidance issued by the Ohio Department of Job and Family Services.
Because WARN Act requirements under federal and state law are highly detailed and fact-specific, employers who are planning large layoffs should be careful and engage in advanced planning, if possible, as violations of both the federal and state law provide affected employees with remedies.
Pay Stub Protection Act — Ohio Revised Code 4113.14
On April 9, 2025, the State of Ohio began requiring that employers provide their employees with more comprehensive, itemized earnings and deductions statements for each pay period. While most employers presumably already provided this information to employees, those that did not must now ensure their employees' pay statements comply with the new law — known as the Pay Stub Protection Act — specifically obligating that employees be provided a "written or electronic statement or access to a statement of the employee's earnings and deductions for each pay period on the employer's regular paydays." R.C. 4113.51.
Under the Pay Stub Protection Act, an employee's pay stub must include: (1) the employee's name; (2) the employee's address; (3) the employer's name; (4) the total gross wages the employee earned during the pay period; (5) the total net wages paid to the employee for the pay period; (6) a listing of the amount and purpose of each addition to or deduction from the wages paid to the employee during the pay period; and (7) the date the employee was paid and the pay period covered by that payment. For hourly employees, the pay stub must also include: (a) the total number of hours the employee worked in that pay period; (b) the hourly wage rate at which the employee was paid; and (c) the hours the employee worked in excess of 40 hours in one workweek.
If an employer does not provide this information as required, the employee can request it and, if it is not provided within ten days, the employee may report the violation to the Ohio Director of Commerce who, upon a finding of reasonable grounds to believe a violation of this law exists, may require the employer to post a notice of the violation for ten days.
Minimum Wage Increase
Legislation passed in 2025 brought about a slight increase in the Ohio minimum wage beginning on January 1, 2026. The new minimum wage for non-tipped employees went up to $11.00/hour (up from $10.70/hour) and the new minimum wage for tipped employees went up to $5.50/hour (up from $5.35/hour). This increase applies to employers with annual gross receipts of $405,000 (up from $394,000). For employers with annual gross receipts of less than $405,000 per year, the state minimum wage remains tied to the federal minimum wage of $7.25/hour.
Employment Posters — Senate Bill 33
Historically, Ohio employers — along with employers nationwide — have been required to display physical copies of posters containing certain rules and regulations informing employees of their legal rights in high-traffic areas (e.g., break rooms) throughout their workspaces.
Ohio law now, however, permits the use of digital labor law posters. Senate Bill 33, which went into effect in July 2025, allows employers to provide certain notices digitally — specifically, those governing: (1) child labor (on the internet in a manner accessible to all employees); (2) minimum wage (on the internet in a manner accessible to all employees); (3) workers compensation (on the internet in a manner accessible to all employees); and (4) civil rights (on the internet in a manner accessible to all employees as well as the public).
For public employers, this law now also permits notification related to prevailing wages and notification related to Ohio's Public Employment Risk Reduction Program (PERRP) to be posted on the internet in a manner accessible to all employees.
Employers who choose to provide notices of these laws electronically must take precautions to ensure that the postings are placed on a reliable platform that employees know how to access, and must further communicate any changes to the manner of display to employees. Notably, this law does not apply to notices required under federal law or any other required posters under Ohio law if not explicitly provided for in Senate Bill 33.
Cleveland's Pay Transparency Act — Cleveland Ordinance 104-2025
Effective October 27, 2025, the City of Cleveland implemented a new pay transparency act designed to address historical pay gaps. Under Ordinance 104-2025, employers with fifteen (15) or more employees must list a salary range for each job posting, and are prohibited from: (1) inquiring into an applicant's salary history; (2) screening applicants based on their current salary or salary history; (3) relying solely on an applicant's salary history in deciding whether to offer employment to the applicant or in determining the salary for the applicant during the hiring process; and/or (4) refusing to hire or otherwise disfavoring, injuring, or retaliating against applicants for not disclosing their salary history.
Cuyahoga County's CROWN Act — Ordinance No. 02025-0004
Cuyahoga County, Ohio implemented its own version of the federal Creating a Respectful and Open World for Natural Hair (CROWN) Act, which took effect on November 13, 2025. This law is enforced by the Cuyahoga County Human Rights Commission. Generally, the new law prohibits discrimination on the basis of hair texture and style (encompassed within discrimination on the basis of race and/or national origin), if such hair texture or style is "commonly associated with a particular race or national origin." Included in the law are non-exhaustive examples such as tightly curled, braids, locs, twists, Afros, and cornrows.
Employers are still permitted to enforce health and safety policies under the law; however, they must exercise caution and ensure that they do so "equally" and without discriminatory intent.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
