On April 7, 2025, the Maryland General Assembly passed HB 102 (“the bill”) to postpone the implementation of Maryland’s Time to Care Act (“FAMLI”) by eighteen months. This is the third time that Maryland FAMLI has been delayed. The bill’s passage follows the Maryland Department of Labor’s (“DOL”) proposed delay, announced in February 2025. The delay will become official upon the signature of Governor Wes Moore, which is expected soon.

The new implementation timeline is as follows:

• Payroll deductions for the state plan will begin January 1, 2027.
• FAMLI benefits to eligible employees will begin January 3, 2028.

It is important to note that payroll deductions were previously set to begin on July 1, 2025, with benefits beginning July 1, 2026.

The DOL is expected to revise their proposed regulations, previously released in November 2024 and January 2025. In their announcement of the proposed delay, the DOL paused all previously communicated regulatory timelines, which included deadlines for applying for a private plan and submissions of wage and hour reports. Presumably, the revised regulations will include updated timelines.

Employer Action

Employers should:

• Adjust their own implementation timeline accordingly.
• Await the publication of revised regulations by the DOL.