Los Angeles Employment Law: City & County Ordinances for Employers

Los Angeles is the second-largest city in the United States, and its employment law landscape reflects that scale and complexity. Over the past decade, the city and county have enacted local minimum wage laws, predictive scheduling requirements for retail workers, expansive fair chance hiring rules, groundbreaking hotel worker protections, healthcare worker minimum wages, and freelance worker safeguards.

For employers, the first challenge is jurisdictional. The City of Los Angeles, unincorporated areas of Los Angeles County, and the 87 other incorporated cities within LA County each may have different rules. An employee who works at a client site in the City of LA on Monday, the employer's office in Burbank on Tuesday, and a job site in unincorporated LA County on Wednesday may be subject to three different minimum wage rates in a single week.

The second challenge is the pace of change. Los Angeles has enacted more local employment ordinances since 2020 than in the prior two decades combined, driven by the COVID-19 pandemic, the hotel worker protection ballot measure (Measure UP), and growing attention to gig and freelance worker rights.

This guide covers the major employment ordinances for the City of Los Angeles and, where applicable, Los Angeles County as of 2026.

### Los Angeles Minimum Wage Ordinance (LAMC Sec. 187)

The City of Los Angeles maintains its own minimum wage that applies to all employees who work at least two hours in a particular week within the geographic boundaries of the City of Los Angeles.

• City of Los Angeles: $17.28/hr (effective July 1, 2024). Adjusted annually on July 1 based on CPI.
• Unincorporated Los Angeles County: $17.27/hr (effective July 1, 2024). Adjusted annually on July 1 based on CPI.

City of LA vs. LA County — the critical distinction: The City of Los Angeles is one of 88 incorporated cities within Los Angeles County. "Los Angeles County" employment laws (including the county minimum wage) apply only to unincorporated areas of the county — communities like East Los Angeles, Willowbrook, Florence-Firestone, and parts of Marina del Rey that are not within any incorporated city. If your employees work in Burbank, Pasadena, Glendale, or any other incorporated city, that city's own minimum wage applies (or the state minimum if the city has not enacted its own).

Practical tip: Use the LA County Registrar-Recorder's "What District Am I In?" tool or the City of LA's ZIMAS system to confirm whether a specific work address is within City of LA limits, unincorporated LA County, or another incorporated city.

Penalties: Back wages, interest, administrative penalties, and potential City Attorney civil enforcement. The City of LA can impose penalties of $120 per employee per pay period for initial violations and $240 per employee per pay period for subsequent violations (LAMC Sec. 187.04).

### Industry-Specific Minimum Wages

#### Healthcare Worker Minimum Wage (SB 525)

California's SB 525 established phased minimum wage increases for healthcare workers statewide, but the practical impact is concentrated in Los Angeles, which has the largest healthcare workforce in the state.

Current rate: $23/hr for large health systems (10,000+ employees) and dialysis clinics as of June 1, 2024, rising to $25/hr by 2028. Other covered facilities follow different phase-in schedules (see the statewide wage-and-hour guide for the full schedule).

Who is covered: "Healthcare worker" is defined broadly to include not only clinical staff but also janitorial, laundry, food service, gift shop, security, and clerical workers employed by a covered healthcare facility.

LA-specific context: Los Angeles County contains over 100 hospitals, thousands of clinics, and the largest concentration of healthcare workers in California. Employers in the healthcare sector must verify their facility classification under SB 525 and track which phase-in schedule applies.

#### Hotel Workers — Measure UP (Proposition HHH / LAMC Ch. XVIII Art. 10)

In November 2024, Los Angeles voters approved Measure UP, a sweeping hotel worker protection ordinance that applies to hotels with 60+ rooms within the City of Los Angeles.

• Minimum wage: Hotel workers must be paid at least $22.00/hr (as of July 1, 2025, subject to annual CPI adjustment). This is significantly above the city's general minimum wage.
• Workload limits for housekeepers: Room attendants cannot be required to clean more than a specified square footage per 8-hour shift. If the hotel requires cleaning above that threshold, the worker must be compensated at 1.5x the regular rate.
• Panic buttons: Hotels must provide personal safety devices (panic buttons) to employees who work alone in guest rooms.
• Recall and retention rights: When a hotel changes ownership, the new owner must retain existing employees for at least 90 days and offer continued employment based on seniority.
• Right to refuse: Hotel workers can refuse to enter a guest room alone if they feel unsafe, without retaliation.

Penalties: Violations are subject to fines of $200-$500 per violation per day, plus back wages and reinstatement for retaliation.

### LA Fair Work Week Ordinance (LAMC Sec. 188)

Effective April 1, 2023, the Los Angeles Fair Work Week Ordinance imposes predictive scheduling requirements on retail employers.

Who is covered: Retail businesses with 300+ employees globally that are primarily engaged in selling consumer goods (NAICS codes 44-45). This includes department stores, grocery stores, drug stores, and other large retailers.

Core requirements:

Good faith schedule estimate: At hiring, provide a written, good faith estimate of the employee's expected schedule, including average hours per week and whether the employee can expect on-call shifts.

14-day advance notice: Work schedules must be posted at least 14 calendar days before the first day of the schedule.

• Changes made with 14+ days notice: no penalty
• Changes made with less than 14 days but 72+ hours notice: 1 hour of additional pay per affected shift
• Changes made with less than 72 hours notice: compensation for half the hours not worked (for shifts reduced or cancelled) or 1 hour of additional pay (for shifts added or changed in time)

Right to rest: Employees can decline to work a shift that begins less than 10 hours after the end of the previous shift. If the employee agrees to work a rest-period-violating shift, the employer must pay a time-and-a-half premium.

Access to hours: Before hiring new employees or using temporary workers, the employer must offer additional hours to existing qualified employees.

Right to request schedule changes: Employees may request changes to their schedule, and the employer must engage in an interactive process. Denial must be based on a bona fide business reason.

Penalties: $500 per violation per employee, plus back pay for any predictability pay owed. Retaliation against employees who exercise rights under the ordinance carries additional penalties.

### LA Fair Chance Initiative for Hiring (LAMC Sec. 189)

Los Angeles's fair chance hiring ordinance (FCIHO) is one of the strongest ban-the-box laws in the nation, with procedural requirements that go beyond both California's statewide Fair Chance Act and many other local ordinances.

Who is covered: Employers with 5+ employees in the City of LA.

Key requirements:

No pre-offer inquiry: Employers cannot ask about, require disclosure of, or conduct a background check on criminal history until after a conditional offer of employment.

1. Conduct an individualized assessment considering the nature and gravity of the offense, time elapsed, and the nature of the job
2. If the employer intends to deny based on criminal history, provide the applicant with a written Fair Chance Assessment identifying the specific conviction(s), the employer's reasoning, and copies of all background check materials
3. Give the applicant 10 business days to respond with evidence of rehabilitation, context, or inaccuracies

This 10-business-day window is the longest response period of any ban-the-box ordinance in California. Compare this to 5 business days under state law and 7 business days under San Francisco's FCO.

Advertising restrictions: Job postings cannot include language such as "no felonies," "background check required," or "must have clean record."

Record retention: Employers must retain all Fair Chance Assessment documents for at least 3 years.

Penalties: $500 for the first violation, $1,000 for the second, and $2,000 for each subsequent violation — per applicant. The City Attorney may also bring civil actions seeking injunctive relief and penalties up to $20,000 per violation.

### Freelance Worker Protections Ordinance (LAMC Sec. 190)

Effective July 1, 2023, the City of Los Angeles enacted protections for freelance workers that require written contracts and timely payment.

Who is covered: Any hiring entity that engages a freelance worker (independent contractor) for services worth $600 or more, either as a single engagement or in the aggregate over a 120-day period.

• Written contract required: The hiring entity must provide a written contract that includes a description of the work, rate and method of compensation, payment date, and date by which the freelance worker must submit a list of services rendered to receive timely payment.
• Timely payment: Payment must be made on or before the date specified in the contract, or if no date is specified, within 30 days of the freelance worker completing the services.
• No retaliation: Hiring entities cannot retaliate against freelance workers who exercise their rights under the ordinance.
• Record retention: Hiring entities must retain copies of all contracts for at least 4 years.

Penalties: The freelance worker can recover double the amount of unpaid compensation, injunctive relief, attorney's fees, and costs. The City Attorney can bring civil actions with penalties of $1,000-$25,000 per violation.

### COVID-Related Retained Worker Rights

While many pandemic-era ordinances have expired, certain retention and recall provisions remain relevant:

Right of Recall (LAMC Sec. 191): Employers in the hotel, event center, airport hospitality, building services, and commercial property sectors with 25+ employees must offer job positions to qualified employees laid off due to COVID-19 before hiring new employees. Offers must be made by seniority. This ordinance has been extended through 2025 and may be further extended.

Worker Retention (LAMC Sec. 192): When a covered business (airport, hotel, event center, commercial building) changes ownership, the successor employer must retain employees from the prior employer for at least 90 days.

Practical note: Even if you believe your business is not covered by these ordinances, verify before assuming they have expired or do not apply to your industry.

### Entertainment Industry-Specific Rules

Los Angeles's entertainment industry is subject to a distinct set of employment rules that layer on top of general employment law:

Minors in entertainment (Labor Code Sec. 1308.5 et seq.): Child performers require entertainment work permits, have restricted working hours, and require a studio teacher when working during school hours. Employers must comply with Coogan Law requirements for trust accounts.

Motion picture/TV industry payroll: Final pay for motion picture industry employees may be made by the next regular payday rather than immediately upon termination (Labor Code Sec. 201.5).

Talent agencies (Labor Code Sec. 1700 et seq.): Must be licensed by the California Labor Commissioner. The intersection of talent agency law and the gig economy (social media influencers, content creators) has created significant compliance questions.

Practical tip: Entertainment industry employers should consult with specialized entertainment labor counsel. The intersection of union agreements (SAG-AFTRA, IATSE, DGA, WGA), state labor law, and local ordinances is uniquely complex.

### Bureau of Contract Administration (BCA)

• Minimum Wage Ordinance
• Fair Work Week Ordinance
• Fair Chance Initiative for Hiring
• Freelance Worker Protections Ordinance

1. Complaint investigations: Employees can file complaints with OWS. Investigations typically include a review of payroll records, interviews, and a calculation of amounts owed.
2. Industry audits: OWS conducts targeted audits of high-violation industries, including restaurants, retail, garment manufacturing, and car washes.
3. City Attorney enforcement: For willful or repeated violations, the City Attorney's office can bring civil actions seeking injunctive relief and substantial penalties.

### Department of Consumer and Business Affairs (DCBA)

For unincorporated LA County, the Department of Consumer and Business Affairs enforces the county minimum wage ordinance.

### Hotel Worker Ordinance Enforcement

Measure UP enforcement is shared between the Bureau of Contract Administration and the City Attorney's office. Hotel workers can file complaints directly or through their union representative.

### Penalty Summary

1. Confusing City of LA with LA County. This is the most frequent mistake. An employer with employees in Culver City, Santa Monica, or Pasadena may assume LA's city ordinances apply — they do not. Conversely, an employer in unincorporated East Los Angeles may not realize LA County's minimum wage applies. Always verify the exact jurisdiction for each work location.

2. Not providing the 10-business-day response period under FCIHO. Employers using a statewide fair chance process with a 5-day response window are violating LA's ordinance, which requires 10 business days. If you run background checks on employees who work in the City of LA, your adverse action process must use the 10-day window.

3. Ignoring the Fair Work Week Ordinance for large retailers. Many national retailers with 300+ employees are unaware that LA's predictive scheduling law applies to their LA stores. The penalties are $500 per violation per employee, and violations are easy to identify across an entire workforce.

4. Treating hotel workers like general employees. After Measure UP, hotel workers in the City of LA have a separate minimum wage, workload limits, panic button rights, and recall protections. Hotels that apply only the general city minimum wage or standard scheduling practices are in violation.

5. No written contracts for freelance engagements over $600. Businesses that regularly engage freelancers, consultants, or independent contractors for $600+ in work are required to provide written contracts with specific terms. The penalty for non-compliance is double the unpaid amount plus potential City Attorney enforcement.

6. Missing the healthcare worker minimum wage phase-in. LA-area healthcare employers must track which SB 525 tier applies to their facility and verify that all healthcare workers — including non-clinical support staff — are paid at the correct rate. The definition of "healthcare worker" is broader than many employers expect.

1. Verify the jurisdiction for every work location. List every address where your employees work within the greater Los Angeles area. For each address, determine whether it falls within the City of Los Angeles, unincorporated LA County, or another incorporated city. Use the LA County Registrar-Recorder's online tool or the City of LA ZIMAS system. Apply the correct minimum wage for each location and confirm your payroll system tracks hours by jurisdiction.

1. Update your fair chance hiring process to the 10-day standard. If any applicants or candidates will work within the City of LA, revise your adverse action notice to provide 10 business days for a response — not the state-mandated 5 days. Update your adverse action letter template, train your hiring managers and background check vendors, and document the revised timeline in your hiring procedures.

1. Audit predictive scheduling compliance for retail locations. If your company has 300+ employees globally and operates retail locations in the City of LA, confirm that you are posting schedules 14 days in advance, tracking schedule changes, calculating and paying predictability pay for late changes, and offering additional hours to existing employees before hiring new staff. Review your scheduling software to confirm it supports these requirements.

1. Review all freelance and independent contractor engagements. Pull a list of every freelance or contractor payment over $600 made in the last 12 months for work performed in the City of LA. For each engagement, confirm that a written contract exists with the required terms. If contracts are missing, create them retroactively where possible and establish a process for generating contracts going forward.

1. Confirm hotel worker compliance if applicable. If you operate a hotel with 60+ rooms in the City of LA, verify compliance with Measure UP: correct minimum wage ($22.00/hr+), housekeeper workload tracking, panic button availability and training, and a documented recall and retention policy. These are not optional — they are enforceable ordinance requirements with per-day penalties.