The Northern Virginia Chamber (NVC) submits these comments in response to the Virginia Employment Commission’s Notice of Intended Regulatory Action (NOIRA) on establishing a Paid Family and Medical Leave (PFML) program under Chapters 981 and 1093 of the 2026 Acts of Assembly. NVC is one of Greater Washington’s and Virginia’s most influential business organizations, today representing close to 500,000 employees and impacting policy across this region and the Commonwealth. Our members have a strong interest in ensuring the resulting regulations to implement the PFML program are clear, workable, and provide employers sufficient time and guidance to comply, and to help employees understand the program. Given the scope, technical complexity, and cost of this effort, especially alongside new paid sick leave requirements, we urge the Commission to prioritize robust stakeholder engagement and to conduct a thorough analysis of the potential costs of implementing this program as it presents a major shift in how Virginia businesses operate.

Because of the scope of the program and its subsequent impact on the cost of doing business in Virginia, employers must be engaged throughout the process in a meaningful way. First and foremost, we need all aspects of this process to be shared in a way that encourages engagement with the private sector. Transparency is key; this process must be done in the open and on a timeline that allows for maximum participation. We believe a robust and comprehensive statewide engagement strategy is needed in order to implement this program in the most effective and least disruptive way possible. Northern Virginia is proudly home to a strong business community representing a diverse set of industries and business sizes and types. In order to be sufficient, implementation must go beyond the minimum required.

We align our comments with those of the Virginia Chamber of Commerce regarding the need for a new actuarial analysis prior to proposing contribution rates. The direct costs of this program will be borne by employers and employees, and all deserve to have the best and most recent cost analysis available when reviewing proposed regulations. This is particularly true when you consider the resources employers need to expend to comply with the program and to inform employees both prior to implementation and going forward during the regular course of business. This is a brand new program, and education will be critical to its implementation.

NVC is grateful for the opportunity to submit these comments to the NOIRA and thanks the VEC for reviewing. Please look to us as a resource as you continue your work to establish the Paid Family and Medical Leave (PFML) program under Chapters 981 and 1093 of the 2026 Acts of Assembly.