Compliance Watch, Issue 04: SECURE plan amendments due December 31, OSHA’s HazCom deadline + 5 more updates

New York personnel-file requests from November 8, a DHS grace-period proposal, Maryland FAMLI deductions and two new California laws for January 1.

RJ Ryan Joyce 5 min read

Pulled from the IRS, DHS, OSHA, the California Legislature and state agencies, then cut down to what matters for your team.

Dates to know

Nov 8-10
Nov 20
OSHA HazCom deadline: employer updates for chemical substances.
Dec 31
Jan 1, 2027

Federal

Three federal deadlines

1
Retirement plans: discretionary SECURE amendments due Dec 31Action before Dec 31 · Retirement plans. An IRS Employee Plans bulletin (September 16) confirms that amendments for the optional SECURE Act and SECURE 2.0 provisions a plan has adopted, such as Roth employer contributions, are due December 31, 2026 for most plans.
What to do: List the optional SECURE and SECURE 2.0 features your plan adopted, such as Roth employer contributions, and confirm with your provider that the amendment will be signed by December 31, 2026.
2
OSHA HazCom: employer updates for substances due Nov 20Action before Nov 20 · Workplace safety. Under OSHA’s updated Hazard Communication Standard, employers have until November 20, 2026 to update, as needed, in-house labels, the written program and training for newly identified hazards in chemical substances.
What to do: If employees work with hazardous chemicals, get updated safety data sheets from suppliers, then update your written program, any in-house labels and training for the new hazards.
3
DHS proposes ending the 60-day grace period after a job endsComment deadline Nov 10 · Immigration. Today a worker in E-1, E-2, E-3, H-1B, H-1B1, L-1, O-1 or TN status whose job ends may get a discretionary grace period of up to 60 days, without working.
What to do: If you employ workers in these categories, plan any job ending with immigration counsel.

California

Two California changes

1
California: bereavement leave can cover a designated personEffective Jan 1, 2027 · Leave. SB 1149 lets employees use California’s bereavement leave, up to five days, after the death of a “designated person”: anyone related by blood or whose association with the employee is the equivalent of a family relationship, whom the employee may name when requesting leave.
What to do: If you have five or more employees, update your bereavement leave policy before January 1, 2027, and decide whether to limit employees to one designated person per 12 months.
2
California: immigration-related retaliation ban expandsEffective Jan 1, 2027 · Retaliation. AB 2495 widens Labor Code 1019’s ban on unfair immigration-related practices to cover retaliation for using rights under federal, state or local laws that protect employees, and conduct tied to perceived immigration status that would reasonably tend to dissuade people from using them.
What to do: Train supervisors that threats or other actions tied to a worker’s immigration status, including after a pay or safety complaint, can bring penalties.

Other states

Two state changes

1
New York: Employees can request personnel files from Nov 8Effective Nov 8 · Personnel records. From November 8, 2026, current and former New York employees can request a free copy of their personnel records in writing and must receive it within five business days.
What to do: Name who handles requests, set a five-business-day turnaround, and add a step to notify employees within 10 days when negative information goes into their file.
2
Maryland: Paid leave contributions start January 1, 2027Effective Jan 1, 2027 · Paid leave. Maryland FAMLI contributions start January 1, 2027: 0.9% of wages up to the Social Security wage cap in total, of which employees can be charged at most 0.45%.
What to do: Register for FAMLI (one registration per EIN), set up the 0.45% employee deduction (or cover it yourself) before your first January 2027 pay date, and notify employees one pay period before January 1, 2027, even if you cover their share.

From our desk

Trump Accounts: the $1,000 head start for kids born 2025 through 2028

Who gets the $1,000 federal seed, how much families can add each year, and what an employer needs in place before contributing.

Trump Account employer rules are still proposed (the IRS hearing was scheduled for October 15); this article covers what an employer needs before contributing.

Also worth knowing

  • New Jersey minimum wage: Most employees: $16.48 an hour from January 1, 2027. Seasonal and small employers (fewer than six employees): $16.25; tipped cash wage: $6.61; long-term care facility direct care staff: $19.48. (NJ Department of Labor)
  • Maine minimum wage: Rises to $15.70 an hour on January 1, 2027. Tipped employees get at least $7.85 in direct wages, and the exempt salary threshold becomes $905.79 a week. (Maine Department of Labor)
  • New York Paid Family Leave: For 2027 the employee contribution is 0.452% of gross wages, capped at $451.81 a year. (NY Department of Financial Services)
  • NLRB discipline standard: Lion Elastomers (Sep 23): the 2020 General Motors test again governs discipline for abusive conduct during protected activity; if the activity motivated it, the employer must prove it would have disciplined anyway. (NLRB)

Questions about this issue?

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If you’re not a client. Every “What to do” line above is a task for someone at your company. Our clients hand the payroll and tax pieces to us and get an HR advisor for the rest.

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More on Compliance Watch

Compliance Watch Compliance Watch, Issue 01: 12 employment rule changes September 11, 2026 Compliance Wire DHS proposes ending the 60-day grace period after a job ends November 2, 2026 Compliance Wire California: bereavement leave can cover a designated person November 2, 2026