St. Paul Minimum Wage Ordinance: Rates and Coverage

Saint Paul’s minimum wage depends on the size of your employer, and during the current phase-in the rates change on two different dates a year rather than one.

That is the main thing to understand about this ordinance. Minneapolis runs a single rate for everyone. Saint Paul runs three size bands moving on separate schedules toward a single rate, which they reach by July 1, 2028. Once a band reaches the City Rate it follows the annual City Rate schedule, so the two-date pattern is a feature of the phase-in rather than a permanent rule.

The Rates Through 2027

Employer size	2026	From January 1, 2027	From July 1, 2027
Large and macro, 101 or more employees, the City Rate	$16.37	$17.02	$17.02
Small, 6 to 100 employees	$16.37 from July 1, 2026	$16.37	$17.02
Micro, 5 or fewer employees	$14.25 from July 1, 2026	$14.25	$15.00
General youth wage, ages 14 to 17	$13.95 from July 1, 2026	Eliminated January 1, 2027	Eliminated

Source: City of Saint Paul, minimum wage and finalized rules for the Minimum Wage Ordinance, reflecting the rates announced September 1, 2026, and Ordinance 26-31. Verified September 5, 2026. These are the city ordinance floors. A higher wage standard under another law, such as the statewide nursing home wage standards effective September 10, 2026, governs where it applies.

Two features of that table are easy to miss. Small and micro employers move on July 1 rather than January 1, so their rate is unchanged for the first half of 2027 and then rises. And micro employers do not reach the City Rate in 2027 at all. They go to $15.00 on July 1, 2027 and reach the City Rate on July 1, 2028, at which point every employer regardless of size is held to the same rate.

The city’s own published tables still separate macro businesses with more than 10,000 employees from large businesses with 101 to 10,000, and both are shown moving to the City Rate on January 1, 2027. The 2027 announcement describes that combined band as large and macro businesses with 101 or more employees. Whichever label you encounter, the operative question is whether your employer has 101 or more employees.

Working out which band your employer falls into is the part that produces most of the disputes. The city counts all employees wherever they are located, generally averages them over the previous calendar year, and excludes owners and board members, so a business with a handful of people in Saint Paul and many more elsewhere is not a micro employer.

Who the Ordinance Covers

The city states that the ordinance covers all employees’ hours of work within the geographic boundaries of the City of Saint Paul, and sets out three points about who that includes.

Full-time, part-time and temporary employees are all covered. Immigration status does not affect coverage. The ordinance does not cover independent contractors, though whether someone genuinely is a contractor turns on the applicable classification tests rather than on what their paperwork says.

Coverage follows the work rather than the employer. An employer located outside Saint Paul owes the applicable city rate for hours its employees work inside the city, and the finalized rules confirm that employees are not covered for hours worked outside the city boundaries.

The rules also resolve how occasional work is treated, and the answer depends on whether you regularly work in the city. Employees who do not regularly work in Saint Paul are covered for hours worked within the boundaries if, over the course of one week, they perform at least two hours of work for the employer inside the city. Employees who regularly work in Saint Paul are covered for their city hours without needing to meet that threshold.

Two related points come from the same rules. Employees traveling through the city and making only incidental stops, such as changing a flat tire or stopping for gasoline, are not covered in those situations. And employees who attend a convention, conference or training in the city but perform no other work for their employer for at least two hours in a week are not covered. Employees working from home are covered where the work is performed inside the city.

What Counts as Wages

The city is specific about this, and the list is broader than base pay.

Wages include salary, hourly pay, piece rate pay, commissions and non-discretionary performance bonuses. Employer payments toward medical benefits and tips are not considered wages.

That second sentence is the one that matters most for tipped workers. Tips do not count toward the Saint Paul minimum wage any more than they count toward the state minimum wage. A restaurant cannot treat a good night in gratuities as satisfying its obligation under the ordinance.

The inclusion of commissions and non-discretionary bonuses cuts the other way and is useful to know if your pay is structured around them. Your earnings statement must show your rate or rates of pay and the basis on which you are paid under Minn. Stat. § 181.032, which is where a commission or bonus that should have counted will first show up.

Rates Are Announced Every September 1

The ordinance requires the City Rate, which applies to employers with 101 or more employees, to be announced by September 1 annually, taking effect on January 1 of the following year.

That gives Saint Paul workers a predictable four-month window of notice, and it is why the 2027 City Rate was public in September 2026. The rate is adjusted using the percentage increase the commissioner of the Minnesota Department of Labor and Industry calculates under Minn. Stat. § 177.24, subd. 1(c), rounded to the nearest cent.

The city’s general minimum wage webpage still displays an older version of this formula that refers to a different subdivision and to the state rate divided by two, which reflects the first year of the phase-in rather than the current method. Where the webpage and the finalized rules differ, the rules and the ordinance govern.

If you are checking your pay in the second half of a calendar year, the following year’s top-band rate is probably already published.

Youth and Training Wages Are Separate

Saint Paul operates youth wage provisions that sit outside the size bands, under Municipal Ordinance § 224.05. One of them is being eliminated.

The general youth wage for 14 to 17 year olds ends on January 1, 2027. Under § 224.05(c), employers could pay employees aged 14 to 17 who were not in a city-approved program at least 85 percent of the City Minimum Wage for small employers for the first 90 days of employment, rounded up to the nearest nickel, which produced $13.95 effective July 1, 2026. Ordinance 26-31 amends § 224.05(c) to eliminate that provisional 90-day rate, effective January 1, 2027. It therefore applies through December 31, 2026 only.

While it remains in effect, two details matter. The 90-day period runs on consecutive days from the date of hire rather than days worked, and an employee must be paid the City Minimum Wage from their 18th birthday even if that falls within the first 90 days. From January 1, 2027, an employee aged 14 to 17 who is not in a city-approved program is owed the applicable City Minimum Wage for their employer’s size band.

The city-approved training and apprenticeship provision survives. Section 224.05(b) continues to cover workers under 20 employed in a city-approved youth-focused training or apprenticeship program, at not less than 85 percent of the city minimum wage for small employers, rounded up to the nearest nickel, or the state minimum wage, whichever is highest. The state training wage and the Minneapolis training exception are different again and do not lower the Saint Paul rate for hours worked in the city.

Notice, Records and Reporting a Violation

Employers must post a notice stating that employees are entitled to the applicable minimum wage, that they have the right to report a violation, and that retaliation for requesting the minimum wage or reporting a violation is illegal. The notice must be somewhere visible and accessible to all employees, provided digitally where employees are primarily remote, and included in any employee handbook. An employer under investigation for violating the ordinance must post a notice of the investigation in the same place.

Section 224.09 sets the recordkeeping duty, and the finalized rules require employers to maintain the information the chapter requires while an employee is employed and for at least three years after the employment ends, and to provide it to the Department on request.

What has to be recorded varies with how you are paid. For hourly employees it includes the hours worked each day and each workweek. For piece-rate employees it includes the number of pieces completed. For commission employees it includes the method used to calculate commissions. Alongside that, the employer must keep the rate and amount paid, earnings statements, employee wage notices and personnel policies.

Two enforcement provisions sit behind that duty. An employer’s failure to maintain, retain or produce records following an administrative search warrant creates a presumption that the employer has violated the chapter, absent clear and convincing evidence otherwise. And where an employer has not kept adequate records and the Department orders back pay, it may determine the amount from available evidence, which the rules describe as including employee testimony, employer and third-party documentation and federal wage estimates.

Complaints go to the Labor Standards Division of the Department of Human Rights and Equal Economic Opportunity at 651-266-8966 or LaborStandards@stpaul.gov. The city states that retaliation against anyone for exercising these rights is illegal, that this includes third-party complainants, and that the division will keep a complainant’s identity confidential to the extent permitted by the investigation.

A city complaint and a private wage claim are separate routes, and the city’s separate Wage Theft Ordinance gives the Labor Standards Division wider enforcement powers over unpaid wages generally. Minnesota law establishes statewide wage floors, while Saint Paul imposes separate city minimum-wage bands for covered work. If another applicable standard is higher, the higher floor controls. Our page on unpaid wages in St. Paul explains what a claim involves. The firm’s St. Paul employment law page covers the other areas we handle in the city.

Frequently Asked Questions

What is the Saint Paul minimum wage in 2027?

It depends on employer size and on the date. From January 1, 2027 it is $17.02 for employers with 101 or more employees, $16.37 for small employers with 6 to 100, and $14.25 for micro employers with 5 or fewer. From July 1, 2027, small rises to $17.02 and micro to $15.00.

Why do the rates change twice a year?

That is a feature of the phase-in. The top band moves on January 1 following the September announcement, while smaller employers were placed on a schedule that steps up each July 1 until they reach the City Rate. Once a band reaches the City Rate it moves with the annual City Rate instead. By July 1, 2028 all employers regardless of size are held to the same rate.

Do tips count toward the Saint Paul minimum wage?

No. The city states that tips are not considered wages for this purpose, and state law separately prohibits any tip credit. You are owed the applicable city rate as wages, with tips on top.

My employer is in Roseville but I work downtown. Which rate applies?

The Saint Paul rate applies to the hours you work within Saint Paul. Coverage follows the location of the work rather than the location of the employer.

How do I find out how many employees my employer has?

Business size is generally the average number of employees per week during the previous calendar year, counting full-time, part-time, joint and temporary employees, including those working outside Saint Paul. If your employer will not tell you, the Labor Standards Division can determine size during an investigation.

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 with the City of Saint Paul before relying on them.