Maryland’s paid family and medical leave program has a name that sounds like a friendly aunt (“FAMLI!”) but a rollout timeline that’s been
more like a suspense series with multiple season finales. The good news: the big pieces are now clearer than everthanks to statutory updates
and a fresh round of proposed regulations that finally get into the “how, exactly, will this work?” details.

This guide breaks down the most important Maryland FAMLI (Family and Medical Leave Insurance) updates, what the proposed regulations say,
what’s still in flux, and what employers and workers should do nowbefore the payroll switches flip and the benefit claims start flowing.
(Spoiler: “wait and see” is not a compliance strategy.)

Note: This article is educational and not legal advice. For decisions that affect payroll, benefits, or policies, consult qualified counsel.

What Is Maryland FAMLI (a.k.a. the Time to Care Act)?

Maryland’s Time to Care Act created a statewide paid family and medical leave insurance program. Instead of requiring each employer to fund
leave individually, the state sets up an insurance-style system funded by payroll contributions. Eligible workers can apply for partial wage
replacement during qualifying leave eventslike welcoming a new child, dealing with a serious health condition, or caring for a family member.

The program is administered by the Maryland Department of Labor (MDOL) through its Family and Medical Leave Insurance Division, and it’s
designed to work alongside other leave frameworks (like federal FMLA, employer PTO, and Maryland’s sick and safe leave rules).
“Alongside” is the key word: stacking leave systems is like stacking pancakesdelicious when done right, messy when rushed.

Key Timeline Updates: The “When Does This Actually Start?” Answer

1) Contributions are now scheduled to begin January 1, 2027

After multiple delays, the current law pushes required payroll contributions to January 1, 2027. That means 2026 is not the
year your payroll team remits FAMLI contributionsbut it is the year you should be building the process, confirming vendor readiness,
and updating policies so you’re not troubleshooting live in January.

2) Benefits will be available no later than January 3, 2028 (and possibly earlier)

Benefits may become available on a date the Secretary of Labor determines and announces, falling between January 1, 2027 and
January 3, 2028. In practical terms, many summaries point to January 2028 as the expected “go-live” for benefit
claimsconsistent with the idea that the program should collect about a year of contributions before paying benefits.

3) The “anchor date” concept matters more than it sounds

Maryland’s law uses an “anchor date” concept to determine certain eligibility and timing issues. In plain English: your benefits math and
eligibility checks may revolve around the earlier of (a) when a benefits application is complete or (b) when leave begins. That can affect
which quarters count for hours-worked eligibility and which benefit maximum applies if the cap changes later.

4) Maximum weekly benefit indexing is delayed

The maximum weekly benefit is widely described as up to $1,000 per week at program start, with future inflation adjustments.
A key statutory change delays inflation-based indexing of the maximum weekly benefit until January 1, 2029. In other words:
for the early years, don’t expect the cap to automatically ratchet upward.

5) Self-employed participation is effectively pushed out

The law contemplates optional participation for self-employed individuals, but the timing is tied to regulations. The updated framework
pushes adoption of self-employed enrollment regulations to July 1, 2028 (at the latest). If you’re self-employed and hoping
to opt in soon, this is the part of the story where the narrator says, “Not yet.”

How Much Leave and Pay Could Workers Receive?

Covered reasons (the “why”)

Maryland’s FAMLI program generally covers leave taken for:

• Bonding with a new child (birth, adoption, foster care, kinship care) in the first year
• Caring for a family member with a serious health condition
• Your own serious health condition that makes you unable to work
• Military-related leave, including care for a service member or qualifying exigency due to deployment

Duration (the “how long”)

Many summaries describe the core benefit as up to 12 weeks of paid leave in a rolling 12-month period, with a potential
pathway to up to 24 weeks in a year if someone experiences both their own serious health condition and also needs bonding leave
for a new child in the same year. Think of it as a “two qualifying events, two buckets” possibilitynot a default.

Wage replacement (the “how much”)

The program is designed to replace a portion of wages, often described as up to 90% of average weekly wages for lower-wage
workers, subject to minimum and maximum weekly benefit amounts. Early-year summaries commonly cite a $50 minimum and a
$1,000 maximum weekly benefit during initial program years, before inflation indexing later.

Example: Suppose a worker has an average weekly wage of $900. If a formula replaces a high percentage (especially at lower wage
tiers), that worker may receive a substantial share of $900 per weekthough never exceeding the program cap. If another worker earns $2,000 per
week, the cap is the ceiling: they may receive the maximum weekly amount rather than their full pay.

Contribution Basics: What Payroll Needs to Know

The contribution rate is cappedand the “initial” rate must be set again

Statutory summaries frequently emphasize that total contributions cannot exceed 1.2% of wages. Maryland previously announced
an initial total contribution rate (widely cited as 0.9% in prior guidance), but updated statutory deadlines require the
Secretary to set the total rate by May 1, 2026 for the contributions that begin January 1, 2027.

Translation: if you’re building 2027 payroll configs, leave room for the final published rate and for how it’s split between employer and
employee shares.

Quarterly reporting and remittance (per proposed regulations)

Proposed regulations describe an employer compliance structure that looks familiar to anyone who has handled unemployment insurance reporting:
employers create an online account, report wages and hours, and remit contributions on a quarterly cadence. Contributions and required wage/hour
reporting are generally due on or before the last day of the month immediately following each calendar quarter.

Concrete example: If contributions start January 1, 2027, then Q1 2027 (Jan–Mar) contributions would typically be due by
April 30, 2027 (unless that date falls on a weekend/holiday, in which case the next business day applies).

Who pays what?

Proposed rules and leading summaries describe a structure where employers remit 100% of the contributions due each quarter,
while withholding up to a defined portion from employees’ wages (often summarized as a 50/50 split of the total rate, unless the employer
elects to cover more). Employers may choose to pay some or all of the employee share, but the proposed regulations emphasize notice and
documentation requirements when employers make that election.

Small employer treatment

A major point for small businesses: employers under a threshold (commonly described as fewer than 15 employees) are generally treated
differently regarding the employer share. Proposed regulations also explain how employer size is determinedby counting employees paid wages,
including those outside Maryland, and using an averaging method over quarters.

Practical takeaway: If you’re near the threshold, don’t guess. Do the count using the rule, document it, and be ready to
support the classificationbecause classification affects what you owe.

Proposed Regulations: What’s New, What’s Detailed, and What Employers Should Watch

Proposed regulations are where programs stop being abstract and start being operational: forms, timelines, notices, and “what happens if we
mess this up?” rules. Maryland’s newest round of proposed FAMLI regulations covers:

• General Provisions (COMAR 09.42.01) definitions, program structure, required templates/forms
• Contributions (COMAR 09.42.02) registration, withholding, reporting, due dates, penalties, overpayments
• Equivalent Private Insurance Plans / EPIPs (COMAR 09.42.03) how to opt out of the state plan with an approved alternative
• Claims (COMAR 09.42.04) how claims are filed, documentation, deadlines, and “good cause” exceptions
• Dispute Resolution (COMAR 09.42.05) reviews, reconsiderations, appeals, and employer liability disputes

1) General Provisions: Definitions that affect real money and real leave

Definitions aren’t fillerthey decide who qualifies. The proposed General Provisions include detailed definitions for items like “application
year,” “domestic partnership,” “family member,” and “serious health condition.” For example, the definition of “family member” is broad and
includes not only children and parents, but also individuals where someone stands in loco parentis and certain guardian/ward
relationships. This matters for HR teams reviewing leave requests and for employees determining whether caregiving leave fits the rules.

Another operational definition: the proposed rules define an “application year” as a 12-month period beginning on the Sunday
of the calendar week in which FAMLI leave begins. That’s a “calendar system” decision that can affect tracking, especially for intermittent
leave.

2) Contributions: Online accounts, wage caps, and the “don’t fix it later” trap

The proposed Contributions chapter does several employer-friendly things (clarity!) and several employer-stressful things (deadlines!).
Highlights include:

• Online account requirement: employers must create and maintain an online account to report and remit.
• Wage base cap: contributions apply to wages up to the Social Security wage base each calendar yearmeaning very high
  earners aren’t endlessly contribution-taxed above that federal ceiling.
• Withholding mechanics: employers may withhold up to the employee share (often described as up to 50% of the total rate),
  and may elect to cover some or all of it, with required written notice.
• Failure to withhold: if an employer fails to deduct the employee share properly, the proposed rules treat the employer as
  having elected to pay that portionand generally prohibit recouping it later (with a narrow exception window tied to pay cycle timing and
  higher-priority withholdings).
• Quarterly schedule: quarterly wage/hour reporting is due on or before the contribution due date, and contributions are due
  by the last day of the month after the quarter ends.
• Penalties and interest: the proposed regulations outline cure periods and potential interest and penalties for delinquencies.

Policy tip: Build an internal “FAMLI payroll checklist” that includes employee notices, withholding start dates, quarter-close
tasks, and a review step for small employer status. The proposed regulations make clear that documentation and timing are part of compliance,
not optional accessories.

3) EPIPs (Equivalent Private Insurance Plans): Opting out isn’t “set it and forget it”

Maryland allows employers to satisfy the program through an approved Equivalent Private Insurance Plan (EPIP)insured, self-insured, or a
combinationso long as the private plan meets or exceeds state plan rights and benefits.

Proposed EPIP rules emphasize:

• Employee protections: EPIPs may not impose extra barriers beyond what the state plan allows.
• Cost limits: employee withholdings under an EPIP cannot exceed what the employee would contribute under the state plan.
• Timing: EPIPs generally cannot start withholding until the policy effective date.
• Administration: EPIPs must have claims processing and dispute procedures aligned with the FAMLI framework.
• Termination consequences: involuntary termination can trigger back payments and other consequences, and the proposed rules
  describe notice obligations and continuation of benefits for already-filed claims.

Reality check: An EPIP strategy can be smartespecially for employers with robust leave benefitsbut it’s not just “buy a plan
and move on.” It’s an ongoing compliance track with reporting, notices, and oversight.

4) Claims: Deadlines, documentation, and a “good cause” escape hatch

The reissued Claims proposal gets very practical: what documentation supports bonding leave, caregiving leave, your own condition, or a
military-related need; how claims are updated; and what happens if you file late.

One of the biggest operational points in the proposed Claims rules:
claim applications generally must be filed within 60 days of taking qualifying leave. The proposal also includes a “good cause”
concept that can waive the deadlineup to one year from leave commencementunder specific circumstances (like a serious health condition that
prevents timely filing or a major system outage).

Employer takeaway: Train managers not to treat FAMLI as “just another PTO request.” Employees may need prompt guidance on
documentation and filing timelines, and employers will need consistent processes to avoid inconsistent treatment across teams.

5) Dispute Resolution: How denials, underpayments, and employer disputes may be handled

Dispute resolution rules are where the program shows its teethbecause they dictate the path when someone says “that’s not correct.”
Proposed dispute resolution procedures outline:

• EPIP denial/termination review: employers may have a short window (e.g., 10 business days in the proposal) to request review.
• Reconsideration and appeals: claimants typically must complete reconsideration before appealing an adverse determination.
• Appeal timing: an appeal window (e.g., 30 days in the proposal), with “good cause” exceptions, and hearing timelines.
• Employer disputes: processes for disputing assessed contribution liabilities.

Why this matters: If your internal leave team or third-party administrator denies a requestor if payroll files the wrong wage
reportthose decisions may become formal disputes. A documented process isn’t bureaucracy; it’s your parachute.

Compliance Checklist: What to Do in 2026 So 2027 Doesn’t Hurt

For employers

• Map your leave universe: Align federal FMLA, Maryland sick/safe leave, PTO, disability plans, and FAMLI processes.
• Confirm employee counts: Determine whether you’re under/over the small employer threshold using the applicable counting method.
• Prep payroll configuration: Plan for a published contribution rate, employee withholding, employer share, and wage base limits.
• Choose your path: Decide whether to join the state plan or pursue an EPIPand price out admin and reporting obligations.
• Train managers: Teach the difference between time off approval and program benefit eligibility (and how not to say the wrong thing).
• Update employee notices: Build templates and communication plans for withholding start, rights, and filing expectations.
• Audit your data pipeline: Wage/hour reporting depends on accurate HRIS and payroll feedsfix mismatches now.

For employees

• Know your qualifying reasons: Bonding, caregiving, your own condition, military-related needs.
• Track paperwork early: Certifications and documentation can take timeespecially for medical leave.
• Watch deadlines: If the claims rule stays similar, timing (like the 60-day filing window) can matter a lot.
• Ask HR the right questions: “How do I request leave?” and “How do I apply for benefits?” may be two different processes.

What This Article Is Based On (No Links, Just Receipts)

This article synthesizes publicly available guidance and analysis from a mix of authoritative and widely cited U.S. sources, including:
Maryland Department of Labor program materials, Maryland Register/COMAR proposed regulations, Maryland General Assembly legislative documents,
and employer/HR compliance analyses from major consultancies and employment law firms (including multi-jurisdiction labor and benefits teams).

Real-World Experiences: What FAMLI Readiness Looks Like (and Feels Like)

The most useful way to understand Maryland FAMLI is to picture what happens inside real workplaces as the program approaches. Below are
experience-based scenarios (composites) that mirror the kinds of issues HR, payroll, and employees routinely face with statewide paid leave
programsespecially when the rules are new, the forms are new, and everyone has “just one quick question” that turns into twenty.

Experience #1: The Payroll Lead Who Discovered “Quarterly” Doesn’t Mean “Whenever We Get to It”

A payroll manager at a 40-person company thought the biggest task would be adding one new deduction line. Then they read the proposed
contribution rules: quarterly wage/hour reports due on a schedule, contributions due by the end of the month after the quarter, and an online
account requirement. Suddenly, this wasn’t a single payroll toggleit was a recurring compliance cycle with deadlines, reconciliation, and
documentation.

The turning point was building a calendar: quarter close + data validation + report submission + payment confirmation. They also created a
“FAMLI folder” (digital, not manilathis is 2026, not 1996) with templates for employee notices, proof of remittance, and internal sign-offs.
When leadership asked, “Can’t we just have the payroll provider handle it?” the payroll lead could answer: “Yes, but we still own the data,
the deadlines, and the audits.”

Experience #2: The Small Employer on the Edge of the 15-Employee Line

A growing small business hovered around the small-employer threshold depending on seasonality. The owner assumed they’d stay “small” because
most staff worked part-time and a few worked out of state. Then the proposed rules clarified that the employee count method could include
employees paid wages inside and outside Maryland, and that “small employer” hinges on the counting methodnot vibes.

Their smart move was to run the count quarterly and document it. Their second smart move was to model cost scenarios: what happens if they’re
“small” this year and not “small” next year? Planning for that possibility meant they weren’t blindsided by an employer-share obligation when
hiring picked up. The surprising lesson: the cheapest compliance strategy is often “accurate classification plus proactive budgeting.”

Experience #3: The HR Generalist Who Had to Explain the Difference Between Leave and Benefits (Gently)

An employee requested time off to care for a parent after surgery. HR approved the time away from workbut the employee assumed that meant
they were automatically paid. HR then had to walk them through the concept that (1) leave approval is about job-protected time off and company
policy coordination, while (2) wage replacement benefits depend on program eligibility, documentation, and the claims process.

The best practice that emerged: HR created a one-page “Two-Step Leave” explainer. Step 1: request leave from the employer (timelines,
scheduling, intermittent leave details). Step 2: apply for benefits (documentation, certification, and deadlines). This reduced confusion and
cut down on the dreaded repeat meetings titled “Quick Sync” that were neither quick nor a sync.

Experience #4: The Employee Who Filed Late (and Learned About “Good Cause”)

Another scenario: a worker took leave for their own serious health condition and didn’t file paperwork quicklybecause they were dealing with,
well, a serious health condition. Under the proposed claims rules, late filing can be a major problem, but “good cause” can potentially waive
the filing deadline in specific circumstances. The employee gathered medical documentation showing prolonged incapacity and was able to explain
why timely filing wasn’t reasonably possible.

The takeaway for workers: don’t assume late filing is automatically forgiven, but also don’t assume it’s hopeless. The takeaway for employers:
when employees face serious medical situations, having a compassionate and consistent process (including clear instructions) reduces both
missed deadlines and workplace friction.

Experience #5: The EPIP Decision That Looked EasyUntil Termination Rules Entered the Chat

A mid-sized employer with strong benefits considered an Equivalent Private Insurance Plan to match or beat the state plan. On paper, it looked
straightforward: pick a plan, apply, and enjoy predictable administration. Then the compliance team looked deeper: employee withholding limits,
timing restrictions on when withholding can begin, notice requirements, claims processing alignment, dispute resolution requirements, and the
consequences if an EPIP is denied or later terminated.

The final decision wasn’t “EPIP or not EPIP,” but “EPIP with a governance plan.” They assigned an owner for quarterly reporting, created a
vendor performance checklist, and wrote an internal escalation path for disputes. The lesson: opting out of the state plan doesn’t mean opting
out of oversightit just changes what you’re responsible for.

If you remember one thing from these experiences, make it this: Maryland FAMLI readiness is less about memorizing the law and more about
operationalizing itcalendar deadlines, clean data, clear employee communication, and a process for when something goes wrong.