The new Minnesota Paid Leave Program is going into effect on January 1, 2026, and if your church employs staff other than pastors it is required to participate in the program. At this point, your church should already have an employer account setup and be reporting wages quarterly. However, details continue to be released as the program launch date nears and there are several things your church should be aware of and considering today.
A significant recent development is related to clergy wages. In the last couple months, MN DEED (Department of Employment and Economic Development) started issuing guidance that any pastors participating in SECA are considered self-employed for MN Paid Leave purposes and are not required to participate, nor is the church responsible for paying premiums on pastors’ compensation. This is a significant change from the guidance they issued when wage reporting first began. Pastors do have the option to “opt-in” to the program under the same conditions as other self-employed individuals, but the church is not responsible for premiums if the pastor chooses to do so. These clarifications also stated churches do not need to report clergy wages going forward.
While pastors are generally excluded, churches are still required to participate in MN Paid Leave if they have any other employees. If your church has employees beyond your pastor, please review the steps outlined on the MN Paid Leave site here. The most immediate deadline is coming on December 1, 2025. Employers are required to notify employees about Paid Leave both individually and by hanging this poster no later than December 1st.
It’s also important for your church leadership to decide how to split the premiums before January 1, 2026. Employers are required to pay at least 50% of premiums and can pay more, up to 100%. Any amount not covered by the employer becomes the employees’ responsibility and gets deducted from their pay. All premiums are remitted by the employer to the state on a quarterly basis. The first premium payments will be due in April 2026 for wages earned in January-March 2026. There is a reduced premium rate for small employers which many churches may qualify for. Use this premium calculator to learn more.
The MN Paid Leave Law allows employers to opt-out ONLY if they offer an equivalent private plan. You can learn more on MN DEED’s equivalent plans page.
We’d encourage you to learn more about the MN Paid Leave Program on the Minnesota Department of Employment and Economic Development (MN DEED) website. We found attorney Virginia Cronin’s update on recent clergy guidance to be helpful along with this article that gives a general overview and highlights things to consider as Paid Leave goes into effect.
If you have questions or are looking for more guidance, feel free to reach out to Kelly Larson, NCD Director of Finance, at kelly.larson@ncdefca.org or call our office at 612-338-1716. We’re here to be a resource for you and will do our best to help!