Michigan benefits compliance: the state rules on top of the federal ones.
Most benefits compliance is federal: ERISA, the ACA and COBRA, all on our compliance calendar. Michigan adds less than many states, but what it adds is easy to miss, and several things people assume Michigan requires, it does not.
Three state rules that reach your benefits program.
Each one applies differently depending on your size and whether your plan is insured or self-funded.
Earned Sick Time
The Earned Sick Time Act, as amended, took effect February 21, 2025. Employees accrue one hour for every 30 worked, up to 72 hours a year, or 40 at employers with ten or fewer employees, who were brought in from October 1, 2025. Our earned sick time guide has the detail.
Minimum Wage and Affordability
Michigan’s minimum wage is $13.73 an hour in 2026 and $15.00 from January 1, 2027. Under the ACA’s rate-of-pay safe harbor, that caps a minimum-wage employee’s self-only contribution at about $177.78 a month in 2026 and $199.29 in 2027. Check yours with the affordability calculator.
State Insurance Mandates
Insured Michigan plans must cover autism treatment, including applied behavior analysis, through age 18, and cap oral chemotherapy cost sharing at $250 per 30-day supply for policies issued or renewed after 2025. Self-funded plans are governed by ERISA and are not subject to these state mandates.
Four things employers often assume Michigan requires.
Getting these wrong usually means spending money or effort on an obligation that does not exist, or missing the federal one that does.
A State COBRA Law
Michigan has no mini-COBRA. An employer with fewer than 20 employees has no state continuation obligation, and federal COBRA starts at 20.
A Paid Family Leave Program
Michigan has not enacted a paid family and medical leave insurance program. Job-protected leave comes from federal FMLA at 50 or more employees, and paid sick time from the Earned Sick Time Act.
A Tax on Self-Funded Claims
The Health Insurance Claims Assessment, a 1% tax on paid claims that reached self-funded plans, was repealed effective October 1, 2018. Its replacement does not apply to self-funded plans.
An Insulin Cost Cap
A bill to cap insulin cost sharing was introduced in 2026, but as of this writing Michigan has not enacted one. Your carrier or pharmacy benefit manager may still offer a lower insulin copay by design. For the largest drug-cost decision in front of employers now, see our GLP-1 coverage guide.
Which rules reach you depends on two things.
Headcount decides most federal obligations, and funding decides whether Michigan’s insurance mandates apply. The compliance deadline checker maps the federal dates.
Ten or Fewer Employees
Earned sick time at 40 hours a year. No COBRA, federal or state. The state insurance mandates apply if your plan is insured.
11 to 49 Employees
Earned sick time at 72 hours a year. Federal COBRA from 20 employees. The ACA employer mandate does not apply yet.
50 or More
The ACA employer mandate and 1094-C/1095-C reporting, federal FMLA, and affordability tested against Michigan wages. Our crossing fifty guide covers the transition.
Insured or Self-Funded
An insured plan is regulated by Michigan’s Department of Insurance and Financial Services and carries the state mandates. A self-funded plan answers to ERISA and the U.S. Department of Labor, not the state insurance code.
Michigan questions, answered plainly.
For the federal calendar, see our compliance page; these are the state-specific ones.
Does Michigan have its own COBRA law?
No. Michigan has no state continuation law for small employers, so a Michigan employer under 20 employees has no continuation obligation. Our page on state continuation laws covers employees in states that do.
Do Michigan insurance mandates apply to our self-funded plan?
No. Self-funded plans are governed by ERISA, which generally preempts state insurance mandates. Autism coverage and the oral chemotherapy cap reach insured plans only.
Does Michigan tax self-funded health claims?
Not since October 1, 2018, when the Health Insurance Claims Assessment was repealed. The assessment that replaced it excludes self-funded plan administrators.
Does Michigan require paid family leave?
No state program exists. Federal FMLA provides unpaid, job-protected leave at 50 or more employees, and the Earned Sick Time Act provides paid sick time at every size.
How does the minimum wage increase affect our contributions?
If you use the rate-of-pay safe harbor, the highest self-only contribution you can charge a minimum-wage employee rises as the wage rises: about $177.78 a month in 2026 and about $199.29 in 2027.
Who handles complaints about an insured plan in Michigan?
The Department of Insurance and Financial Services regulates insured plans and takes consumer complaints. Self-funded ERISA plans fall under the U.S. Department of Labor.
Are Michigan small-group rates filed with the state?
Yes. Carriers file small-group rates with the Department of Insurance and Financial Services, which is why the filed rate for a given plan cannot be negotiated at renewal. What can change is what a second opinion on your renewal looks at.
We have employees in Michigan and other states. Whose rules apply?
It depends on the rule. Insurance mandates generally follow the state where an insured policy is issued, while sick-leave and wage laws follow where each employee works. Multi-state groups usually need a map of both.
Does Michigan require a special notice about health benefits?
We are not aware of a Michigan-specific health benefits notice. The Earned Sick Time Act does require written notice to employees, and every federal notice still applies.
Does Michigan’s autism mandate have an age limit?
Yes. For insured plans, the mandate covers diagnosis and treatment through age 18.
Ready? Send us your renewal, or talk it through with someone first. No cost, no obligation.
General information about Michigan benefits compliance, not legal advice. Plan-specific questions belong with ERISA counsel, and we will bring them in.
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
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