Providing Developments & Insight on Trending Topics in Employment Law

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Providing Developments &amp; Insight on Trending Topics in Employment Law

Late last year, the Los Angeles City Council considered an amendment to the Hotel Minimum Wage Ordinance. On March 7, 2025, the Los Angeles city attorney (City Attorney) submitted a draft ordinance to the City Council, pursuant to the Council’s Dec. 11, 2024 approval of a motion to amend the Living Wage Ordinance, which regulates wages for airport workers, and the Hotel Worker Minimum Wage Ordinance, which regulates wages for hotel workers. On April 14, 2025, the City Attorney issued a revised draft ordinance containing only minor technical corrections and no substantive changes. The Los Angeles Economic Development and Jobs Committee reviewed and approved the ordinance on May 6, 2025. Although not yet officially implemented, the draft ordinance includes several important provisions that the hospitality industry should track closely:

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Increased Minimum Wages for Hotel and Airport Workers.&nbsp;The draft amendments to the Living Wage Ordinance and the Hotel Worker Minimum Wage Ordinance will increase the minimum wage for airport and hotel workers to $22.50 per hour by July 1, 2025, with annual increases to $30 per hour by July 1, 2028.

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Healthcare Benefits Rates. This is the most jarring financial increase that the L.A. hotel industry may suffer under the proposed legislation. Applicable hotel and airport employers will be required to provide airport and hotel workers a minimum healthcare benefits payment at the rate of $8.35 per hour starting on July 1, 2025. In theory, the value of employer healthcare benefits is reduced to a per-hour dollar value, and then the difference below the $8.35 threshold is paid out in an additional wage supplement. For instance, an employer that does not provide an employee with healthcare benefits must pay the employee an additional wage rate of $8.35 per hour.

Required Training for Housekeeping Staff.&nbsp;Applicable hotel employers will be required to ensure that each housekeeping employee attends a public housekeeping training provided by an outside agency certified by the Los Angeles Office of Wage Standards. The training will cover topics such as effective cleaning techniques, best practices for identifying and responding to suspected instances of human trafficking, and hotel workers’ rights and hotel employers’ responsibilities under Los Angeles’s Hotel Worker Protection Ordinance. Notably, hotel employers will be required to cover the cost of the training and pay employees their applicable wage rate for time spent in training.

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Additionally, on April 14, 2025, the Los Angeles chief legislative analyst (Chief Legislative Analyst) submitted reports to the City Council on several topics they had been directed to investigate in connection with the proposed amendments to the Living Wage Ordinance and the Hotel Worker Minimum Wage Ordinance. Although none of the findings or recommendations from these reports are reflected in the City Attorney’s draft ordinance, there are a couple of subject areas that employers should monitor in case the City Council directs the City Attorney to incorporate them into the ordinance:

A Carve-Out for Restaurant, Spa and Retail Tenants.&nbsp;In reviewing alternative policy recommendations for restaurants, spas and retail businesses that lease space in hotels, the Chief Legislative Analyst presented several options for the City Council to consider. These included revising the current definition of “hotel workers” to exclude those not directly employed by the hotel, providing an exemption for commercial lessees operating as separate businesses within hotel properties, and granting a more generous exemption from wage increases to lessee employers who can demonstrate financial hardship.

Limitations on Subcontracted Housekeeping Services.&nbsp;The Chief Legislative Analyst was also instructed to examine options for limiting hotel housekeeping subcontracting, including collecting data regarding a recent New York City ordinance approved last November that prohibits new subcontracting for hotel housekeeping services under the guise of guest and employee “safety.” The Chief Legislative Analyst’s report noted that it is unclear whether Los Angeles could adopt provisions similar to those in the New York City ordinance without first establishing a licensing process for hotel operators and a department responsible for issuing and enforcing such licenses. The report also highlighted that New York City’s use of its police power to enforce the subcontracting provision relies heavily on law enforcement findings and reports of widespread illicit activity and risks to workers and the community. Any similar expansion of Los Angeles’s police power to restrict subcontracting would likewise require comparable findings from law enforcement to justify such action.

The timeline for this proposed ordinance is still a bit unclear. The City Council has not responded to the draft ordinance or the Chief Legislative Analyst’s reports. We do not know when a City Council vote will occur, nor do we know when those changes might go into effect if passed. Based on the current timeline, we expect the City Council to begin discussions on the draft ordinance late this month.

With that in mind, savvy hotel owners and operators should be considering moves to be made now, anticipating the passage of the ordinance in the near future.

Please find a link to the current draft ordinance&nbsp;<a href="https://urldefense.proofpoint.com/v2/url?u=https-3A__clkrep.lacity.org_onlinedocs_2014_14-2D1371-2DS13-5Fmisc-5F04-2D14-2D25.pdf&amp;d=DwMGaQ&amp;c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&amp;r=Uy6b4bxbwqRviqjhJ6PSDrz6x7Na_GFGzULOI_iGgNc&amp;m=yWm8dFa417wI9OrX5cxFs7A1Eai0UKqpiFkdbYqoSgDYl2uYehTmRWZ4UVqFvD20&amp;s=orP0whgDH96mVMxU0DIzr156XlP1sGw70Z7uxxtgHQ4&amp;e=">here</a>, and a link to the Chief Legislative Analyst’s reports&nbsp;<a href="https://urldefense.proofpoint.com/v2/url?u=https-3A__clkrep.lacity.org_onlinedocs_2014_14-2D1371-2DS13-5Frpt-5Fcla-5F04-2D14-2D25.pdf&amp;d=DwMGaQ&amp;c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&amp;r=Uy6b4bxbwqRviqjhJ6PSDrz6x7Na_GFGzULOI_iGgNc&amp;m=yWm8dFa417wI9OrX5cxFs7A1Eai0UKqpiFkdbYqoSgDYl2uYehTmRWZ4UVqFvD20&amp;s=X-yqsqGoqKtHgcCmjxJksM6UcUIFSEne2E1zqm6RR5I&amp;e=" target="_blank" rel="noreferrer noopener">here</a>.

Update: Los Angeles City Attorney Submits Draft Ordinance to Amend Minimum Wage for Hotel and Airport Workers