Do predictive scheduling laws apply to hotels?

If you run one independent hotel, almost certainly not — though not for the reason most operators assume. It is not that hotels are carved out. It is that predictive scheduling laws set a floor on employer size, and that floor is counted across the whole company rather than the one building you run. A 90-room property with 38 people on the payroll is under every threshold in the country. A management company with nine of those properties may not be.

One state and a handful of cities have passed these laws, and most of them cover retail and fast food and stop there. Five reach hotels.

Which predictive scheduling laws reach hotels

Two things in that table are worth more than the rest of it.

Seattle’s exclusion is a classification question, not a size one. The city’s own guidance addresses the case of a restaurant inside a hotel: where the restaurant operates under the hotel’s business license and therefore carries a hotel NAICS code rather than a food-service one, it falls outside the Secure Scheduling Ordinance. Two restaurants on the same block can land on opposite sides of the line based on how the business was registered. If you are anywhere near a boundary like that, the answer is in your licensing paperwork, not in a summary like this one.

Evanston’s threshold is widely misreported, and the reason is instructive. The ordinance was introduced in early 2023 with a coverage floor of 15 employees. An amendment raised it to 100 before the council passed it in May of that year. The 15 never took effect — but it is still in circulation, in contemporaneous news coverage of the debate and in commentary written from that coverage, so a search returns both numbers with roughly equal confidence. The enacted figure is 100 or more employees globally. A number repeated often enough starts to feel verified; on a question like this, the ordinance text is the only thing that actually is.

The threshold counts the employer, not the hotel

This is the part that decides most of these questions, and it is the part that surprises people.

Oregon’s 500 is worldwide, across every entity the employer operates. Chicago’s 100 is global, with a second test — at least 50 employees who are themselves “covered,” meaning they work in a covered industry and earn at or below a wage line that moves every July. As of 1 July 2026 that line is $33.85 an hour, or $64,945.55 a year. Philadelphia’s test is a pair: 250 employees and 30 locations worldwide.

So the arithmetic runs in a direction that catches portfolios rather than single properties. Nine limited-service hotels averaging 40 employees each is 360 people — under Oregon’s 500. Thirteen of them is 520, and the fourteenth property does not need to be large for the thirteenth to have already crossed the line. Nobody at any single hotel notices the day it happens.

The mirror image also holds: a genuinely large single hotel — a 400-room full-service property with three restaurants — can clear Chicago’s thresholds on its own.

If posting two weeks out and keeping the posted version legible is the part you are weakest on, see how scheduling works.

What being covered actually costs

The requirements rhyme across jurisdictions: post the schedule in advance, pay a premium when you change it, and let people decline a shift that starts too soon after the last one. The numbers differ.

Chicago. Fourteen days’ notice. Change a shift, add hours, or cancel with more than 24 hours’ notice and the employee is owed one hour of predictability pay on top of wages earned. Cancel or cut a shift with less than 24 hours’ notice and they are owed at least 50% of the pay for the scheduled hours they lose. An employee may decline any shift beginning less than 10 hours after the previous one ended — and under the rules effective 1 June 2026, a shift worked inside that window pays at least 1.25× the regular rate whether or not the employee asked for it or agreed to it. That last part is the trap: consent used to look like the deciding factor and no longer is. Chicago revised these rules on 1 June 2026, so a compliance memo written before then is out of date.

Oregon. Fourteen days’ notice. Add a shift and it is one hour of pay at the regular rate, on top of wages earned. Cut hours or move a shift so that scheduled hours are lost, and it is half the regular rate for each hour lost. Ten hours of rest between shifts, with time-and-a-half for hours worked inside that window.

Philadelphia. Fourteen days’ notice, raised from ten on 1 January 2021. Nine hours of rest between shifts unless the employee consents in writing and is paid $40 for it.

A worked example, invented: a room attendant in Chicago is scheduled 8:00 to 16:00 on Saturday. Friday evening, a block cancels and you cut her to four hours. That is inside 24 hours, so she is owed 50% of the pay for the four hours removed — about $38 at $19 an hour. Once, that is a rounding error. Do it to six people across a soft week and it is $228, plus the more consequential change: the schedule you posted a fortnight ago is now a document with legal weight, and “we adjusted it” is a thing you have to be able to evidence.

The rules that reach you whether or not you are covered

Falling under every predictive scheduling threshold does not mean the shape of a schedule costs nothing.

Reporting-time pay in California applies to hotels and motels of any size. Under Wage Order 5, which governs the Public Housekeeping Industry, an employee who reports for work as required and is either not put to work or given less than half the scheduled day is owed half the scheduled day — never fewer than two hours, never more than four, at the regular rate. Called in a second time the same day and given under two hours? Two hours’ pay. Sending someone home at 10am because the house came in soft has a price attached, and it does not care how many properties you own.

Hotel worker protection ordinances are a separate category that targets hotels directly, which predictive scheduling laws mostly do not. Los Angeles County’s, operative 1 April 2026 in unincorporated county areas, is not a predictive scheduling law but constrains the schedule anyway: a covered employee cannot be required to work more than 10 hours in a day without written consent given after at least seven days’ notice. It also caps cleaning square footage per eight-hour shift — 4,500 sq ft at hotels under 40 rooms, 3,500 at 40 rooms and above — with double pay above the cap, and adds a housekeeping training requirement from 1 October 2026. The City of Los Angeles has had its own hotel worker ordinance since 2022 covering similar ground, so “the county rule” and “the city rule” are two different documents and the one that binds you depends on which side of a boundary the property sits.

And in the states with a daily overtime rule, the length of a shift is a payroll number in its own right, which we worked through separately in daily overtime rules by state. The coverage arithmetic underneath all of it — how many people you need on the floor before you start shaping their days — is the subject of how many housekeepers a 40-room motel needs.

The honest limits

This is not legal advice, and none of the above tells you whether you are covered. These ordinances are amended often, several thresholds index annually, coverage frequently turns on industry classification rather than headcount, and a collective bargaining agreement can displace parts of them. Confirm against the ordinance text and the enforcing agency, and involve an employment lawyer before you restructure anything.

Each of these is published by the agency that enforces it, which is where to check rather than here:

• Oregon — BOLI, predictive scheduling
• Chicago — Office of Labor Standards, Fair Workweek
• Philadelphia — Fair Workweek Employment Standards, Phila. Code ch. 9-4600
• Berkeley — Fair Workweek Ordinance FAQ
• Evanston — Fair Workweek ordinance
• Seattle — Secure Scheduling
• California — IWC Wage Order 5, Public Housekeeping

What software helps with here is narrower than the category usually implies. A scheduling system can hold the posted schedule, resolve every date in the property’s own timezone rather than the server’s or the reader’s, and show what was actually worked against what was published. That is the evidentiary half of the problem, and it is real.

It cannot tell you whether your employer count crossed 500 last quarter, and any product that offers to calculate your predictability pay is claiming to track a dozen ordinances that change on different schedules — worth asking which ones, and when the rules behind them were last reviewed. ProfitClock does not compute predictability pay, and we would rather say so than let the question go unasked.