October 22, 2026 | Employment

Which Employment Laws Apply to Your Arizona Employer? Thresholds at 1, 15, 20, 50, and 100 Employees

Whether a law protects you, or binds you as an owner, often turns on one number: how many people the employer has. In Arizona, the minimum wage, earned paid sick time, the wage-payment statute, workers' compensation, the sexual-harassment rule, and the wrongful-termination statute all apply from the first employee. The federal and state discrimination laws start at fifteen. Age discrimination and health-coverage continuation start at twenty. Family and medical leave starts at fifty. Plant-closing notice starts at one hundred. The tables below put each law at its threshold with the section cited, then explain how the count is done, because the count itself is where disputes start.

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From the first employee

LawWhat it requiresStatute
Arizona Minimum Wage Act$15.15 an hour statewide in 2026, adjusted each January for inflation; Flagstaff and Tucson set higher local minimumsA.R.S. § 23-363
Earned paid sick time (Fair Wages and Healthy Families Act)One hour accrued per 30 hours worked; use capped at 24 hours a year under 15 employees, 40 hours at 15 or moreA.R.S. § 23-371 and § 23-372
Wage payment and treble damagesPay on regular paydays; final wages within seven working days or the next regular payday when fired; up to three times wrongfully withheld wagesA.R.S. § 23-351, § 23-353, § 23-355
Workers' compensation insuranceRequired of every employer with one or more employees, with narrow exceptionsA.R.S. § 23-902
Sexual harassment under the Arizona Civil Rights ActACRA's harassment and related retaliation provisions reach an employer with one or more employees, even though its general discrimination provisions start at fifteenA.R.S. § 41-1461(7)
Arizona Employment Protection ActTermination in breach of a written contract, in violation of a statute's public policy, or for refusing to break the law or for whistleblowing is actionableA.R.S. § 23-1501
Legal Arizona Workers ActEvery employer must use E-Verify for new hiresA.R.S. § 23-214
Medical marijuana cardholder protectionNo discipline for cardholder status or a positive test alone, with exceptions for impairment at work and safety-sensitive positionsA.R.S. § 36-2813
Federal: FLSA overtime and minimum wageCovers most employers through enterprise coverage ($500,000 in annual sales) or individual coverage of employees in interstate commerce29 U.S.C. § 203, § 206, § 207
Federal: Equal Pay Act, OSHA, USERRA, immigration (I-9)Apply regardless of headcount29 U.S.C. § 206(d); 29 U.S.C. § 654; 38 U.S.C. § 4301 and following; 8 U.S.C. § 1324a

Arizona has no state family-leave statute, no state plant-closing statute, and no general right for a private-sector employee to inspect a personnel file. Where those protections exist, they are the federal laws below, at the federal thresholds.

At 15 employees

LawWhat it requiresStatute
Arizona Civil Rights Act (general)No discrimination in hiring, pay, terms, or discharge on the basis of race, color, religion, sex, age, disability, national origin, or genetic informationA.R.S. § 41-1461(7)(a), § 41-1463
Title VII of the Civil Rights Act of 1964Same protected classes at the federal level, including pregnancy and sexual orientation and gender identity as sex discrimination42 U.S.C. § 2000e(b)
Americans with Disabilities Act, Title IReasonable accommodation and no disability discrimination42 U.S.C. § 12111(5)
Pregnant Workers Fairness ActReasonable accommodation for pregnancy, childbirth, and related conditions42 U.S.C. § 2000gg(2)
Genetic Information Nondiscrimination ActNo use of genetic information in employment decisions42 U.S.C. § 2000ff(2)
Earned paid sick time, higher capUse cap rises from 24 to 40 hours a yearA.R.S. § 23-372(A)

The fifteen-employee count under ACRA and Title VII is fifteen or more employees for each working day in twenty or more calendar weeks in the current or preceding year. Part-time employees count. Owners who are also employees may or may not, depending on how the business is organized, which is a common point of dispute in small-firm cases.

At 20 employees

LawWhat it requiresStatute
Age Discrimination in Employment ActNo discrimination against workers 40 and older; sets the 21-day and 45-day review periods and 7-day revocation for age-claim waivers in severance agreements29 U.S.C. § 630(b); § 626(f)
COBRAOffer continuation of group health coverage after a qualifying event, generally for 18 months29 U.S.C. § 1161
Arizona mini-COBRA (below 20 employees)Employers with 1 to 19 eligible employees must offer continuation coverage under state law insteadA.R.S. § 20-2330

ACRA covers age discrimination from fifteen employees, so an Arizona worker at a sixteen-person company has a state age claim even though the federal ADEA does not apply until twenty. The severance-review windows are federal and depend on ADEA coverage, but many employers below twenty offer the 21 days anyway because the form is standard.

At 50 employees

LawWhat it requiresStatute
Family and Medical Leave ActUp to 12 weeks of job-protected unpaid leave a year for the employee's own serious health condition, a family member's, a new child, or military exigencies; 26 weeks for military caregiver leave29 U.S.C. § 2611(4)
Affordable Care Act employer mandateOffer affordable coverage to full-time employees or pay an assessment26 U.S.C. § 4980H
Affirmative action plans (federal contractors)Written plans for contractors with 50 or more employees and a qualifying federal contract41 C.F.R. part 60-2

FMLA has two counts. The employer must have 50 or more employees in 20 or more workweeks in the current or preceding year, and the employee must work at a site where the employer has 50 employees within 75 miles. The second count is where Arizona workers at small branch offices of large companies lose coverage. The employee must also have worked 12 months and 1,250 hours.

At 100 employees

LawWhat it requiresStatute
Worker Adjustment and Retraining Notification Act (WARN)60 days' written notice before a plant closing or mass layoff; pay and benefits for the notice period if notice is not given29 U.S.C. § 2101(a)
EEO-1 reportingAnnual workforce demographic report to the EEOC (also required at 50 employees with a qualifying federal contract)29 C.F.R. § 1602.7

WARN counts 100 or more full-time employees, excluding those who have worked under six months or under 20 hours a week, and triggers on a plant closing affecting 50 or more employees at a single site, or a mass layoff of 50 or more employees making up a third of the site, or 500 or more regardless. Arizona has no state WARN act, so layoffs below these numbers carry no notice requirement beyond what a contract or policy provides.

How the count is done, and why it is contested

Most thresholds count employees on the payroll, full-time or part-time, for a stated number of weeks in the current or prior year, not the number on the day of the event. Temporary and leased workers can count toward the user company under joint-employment rules. Independent contractors do not count, which is one more reason misclassification matters: an employer that calls fourteen of its twenty workers contractors may be claiming to sit below every threshold on this page.

Related companies can be combined. Under the integrated-enterprise test, two entities with common ownership, common management, interrelated operations, and centralized control of labor are counted as one employer, so a restaurant group of three ten-person LLCs can be a thirty-employee employer for Title VII and ACRA.

If you are not sure whether a law reaches your employer, the facts that settle it are the ones on the payroll records, and the short filing deadlines in the discrimination laws (180 days at the Arizona Civil Rights Division, 300 at the EEOC) do not wait for the question to be answered. A licensed Arizona attorney can review the count and the deadline; asking is free.

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