- Date:
- Category: Wage and Hour
Saint Paul sets three minimum wage rates based on how many people your employer employs. Count 101 or more and the City Rate applies. Count 6 to 100 and the small employer rate applies. Count 5 or fewer and the micro rate applies.
The count is where this gets interesting, because the city counts employees your employer may not expect it to count, including people who never set foot in Saint Paul.
You can reach out to us by calling (844) FERRARO.
The Full Schedule
| Employer size | 2026 | From January 1, 2027 | From July 1, 2027 | From July 1, 2028 |
|---|---|---|---|---|
| 101 or more employees, the City Rate | $16.37 | $17.02 | $17.02 | City Rate |
| Small, 6 to 100 employees | $16.37 from July 1, 2026 | $16.37 | $17.02 | City Rate |
| Micro, 5 or fewer employees | $14.25 from July 1, 2026 | $14.25 | $15.00 | City Rate |
Source: City of Saint Paul, minimum wage and finalized rules for the Minimum Wage Ordinance, reflecting the rates announced September 1, 2026. Verified September 5, 2026.
Read down the January 1, 2027 column and you can see why this page exists. On that date three different rates apply in the same city, and the gap between the top and the bottom is $2.77 an hour. For someone working full time, that is a difference of more than $100 a week depending on a headcount they may know nothing about.
How Business Size Is Actually Counted
The city’s counting rules are broader than they first appear, and several of them work in the employee’s favor.
Everyone counts, wherever they are. Employers must count all full-time, part-time, joint and temporary employees, and must include employees who are not located in Saint Paul. A company with four people in its Saint Paul shop and ninety elsewhere is not a micro employer.
The measure is an average over the prior year. Business size is generally based on the average number of employees per week during the previous calendar year.
Owners and board members do not count. They are excluded from the calculation.
Titles do not change the answer. The city states directly that employers may not mask employees with titles to change their business size.
That last rule exists because the incentive to be one band lower is obvious. If your employer reclassified a group of workers as something other than employees around the time a rate step approached, that is worth raising, and it overlaps with the classification questions covered on our misclassification page.
New Businesses, Joint Ventures and Franchises
Three situations have their own counting rules.
A new business calculates its size from the average number of employees per week during the first 90 days after the first employee started working, under rule 6.3 of the city’s finalized rules. For the 90-day period before that calculation takes effect, the employer must make a reasonable, good faith effort to estimate its projected number of employees and pay the applicable minimum wage in the meantime.
The city’s general webpage still describes a 13-week calculation for new businesses. The finalized administrative rules use the 90-day rule, and where the two differ the rules and the ordinance govern.
Integrated enterprises and joint ventures count as one employer. Size is calculated by adding the employees of all businesses involved, counting jointly employed people only once. The Labor Standards Division determines whether an integrated enterprise exists by assessing the degree of control one entity exercises over another, and the city lists the factors it weighs: the degree of interrelation between operations, the degree to which the entities share common management, centralized control of labor relations, and the degree of common ownership or financial control.
Franchises count across locations. For a franchise, the calculation covers the total number of employees at all franchise locations owned and operated by a single franchisee. Franchise relationships involving more than two parties are treated as integrated enterprises and must count the employees of all sub-franchises. The city places the burden on the employer to establish that it is not an integrated enterprise if it disagrees with that classification.
That burden allocation is worth noticing. Where the classification is contested, the employer is the one the rules require to produce documentation.
The Restaurant Exception
Section 224.06(e) provides that, except for franchises, each full-service restaurant location in Saint Paul with fewer than 10 locations nationally is treated as a unique employer solely for the purpose of determining business size.
The calculation is different too. Rather than counting the enterprise as a whole, the employer adds the number of employees from each location separately per week for 52 weeks and divides by 52. If there is only one Saint Paul location, only that location’s employees are counted, and employees at other locations outside Saint Paul do not need to be included, provided the restaurant has fewer than 10 total locations.
The conditions are narrow: full service, located in Saint Paul, fewer than 10 locations nationally, and not a franchise. The finalized rules define a full-service restaurant as one with seated service. If your employer is relying on this to place itself in a lower band, the question is whether it meets all four conditions.
What “Large” and “Macro” Mean on the City’s Own Tables
You will encounter both words and they can be confusing.
The city’s published rate tables still list Macro Businesses, meaning 10,001 or more employees, and Large Businesses, meaning 101 to 10,000, as separate rows. Both rows show the City Rate from January 1, 2027. The city’s 2027 rate announcement refers to the combined group as large and macro businesses with 101 or more employees.
For working out your own rate, the distinction has no consequence. Everything at 101 employees and above is on the City Rate. The separate rows reflect the phase-in history, when macro employers led the schedule and reached $15.00 on July 1, 2022 ahead of everyone else.
The ordinance is Chapter 224 of the Saint Paul Legislative Code, adopted unanimously by the City Council on November 14, 2018, with the City Rate provision at § 224.04 and the size definitions at § 224.02.
When the Tiers Disappear
July 1, 2028. From that date the city’s finalized rules provide that all employers regardless of size are held to the same rate, the City Rate.
Micro employers are the last to arrive, moving to $15.00 on July 1, 2027 and to the City Rate a year later. Small employers get there on July 1, 2027. The city-approved youth training and apprenticeship rate under § 224.05(b) remains separate and is not folded into that convergence. The general youth wage for 14 to 17 year olds under § 224.05(c) is a different matter: Ordinance 26-31 eliminates it effective January 1, 2027.
Small employers reach the City Rate on July 1, 2027 and then follow the City Rate schedule, which the ordinance provides for them beginning January 1, 2028. Micro employers continue on the July schedule until they converge in 2028.
Until the phase-in finishes, the band question is a live one every July and every January, and it is worth rechecking your rate on both dates rather than assuming your pay moved when it should have.
If You Are Being Paid the Wrong Tier
Paying the micro rate when the employer belongs in the small band, or the small rate when it belongs at 101 or more, produces an hourly shortfall for every hour worked in the city. Across a year, that can be a substantial sum, and a band applied incorrectly can affect other employees at the location as well.
Two routes exist. The Labor Standards Division can investigate and pin down the correct business size, which is often the practical answer where the headcount is genuinely unclear from outside. Alternatively, a private wage claim under Minn. Stat. § 177.27, subd. 8 puts the employer on the hook for the full shortfall plus a matching sum in liquidated damages, and subdivision 10 makes the employee’s costs and attorney fees part of the judgment, not optional.
Timing matters. Wage claims like this one generally reach back two years under Minn. Stat. § 541.07, clause (5). That window grows to three years if the employer failed to turn over payroll records the department requested by a set deadline, or if the underpayment was willful rather than an honest mistake, so either avenue is worth checking before assuming older pay periods are out of reach.
The employer’s location does not itself determine coverage. Employees who regularly work in Saint Paul are covered for their city hours, while employees who do not regularly work there generally must perform at least two hours of work in the city during the week. Minnesota law establishes statewide wage floors, while Saint Paul adds size-based city minimum-wage bands. A higher industry-specific standard controls where it applies. If you are being underpaid, our page on unpaid wages in St. Paul explains what a claim involves, and the firm’s St. Paul employment law page covers the other areas we handle.
Frequently Asked Questions
How do I know which size band my employer is in?
Business size is generally the average number of employees per week over the previous calendar year, counting all full-time, part-time, joint and temporary employees including those working outside Saint Paul, and excluding owners and board members. If you cannot establish the number from outside, the Labor Standards Division can determine it during an investigation.
My employer only has four people in Saint Paul. Is that a micro business?
Not necessarily. Employees who are not located in Saint Paul still count toward the total. A business with four local employees and ninety elsewhere is a small employer at minimum, and possibly larger.
Does each franchise location count separately?
For a franchise, the count covers all locations owned and operated by a single franchisee. Franchise relationships with more than two parties are treated as integrated enterprises and must count employees of all sub-franchises. The narrow exception for separate counting is full-service restaurants with fewer than 10 locations nationwide, which excludes franchises.
When does my rate go up?
That depends on your employer’s band and on where the phase-in has reached. The 101-or-more band moves on January 1 with the City Rate. Small and micro employers step up on July 1 until they reach the City Rate, after which they move with the City Rate on January 1. Both dates are worth checking, because a rate step that should have applied to you and did not is an hourly shortfall from that date forward.
What happens after 2028?
From July 1, 2028 the city’s finalized rules hold all employers, regardless of size, to the same rate. The size bands stop mattering for the base rate at that point. The separate city-approved youth training and apprenticeship rate under § 224.05(b) remains, while the general youth wage for 14 to 17 year olds under § 224.05(c) is eliminated on January 1, 2027.
This article provides general information about the Saint Paul Minimum Wage Ordinance and Minnesota law and is not legal advice. Rates change on January 1 and July 1 and are announced each September 1, and this page is reviewed on that schedule. Confirm current figures and your employer’s classification with the City of Saint Paul before relying on them.
