As of January 1, 2026, New York's Healthy Terminals Act covers private-sector workers who spend at least half of their time in any work week at JFK or LaGuardia, or at a location that prepares or delivers food for aircraft departing them[1]. Workers employed in an executive, administrative or professional capacity are outside it, as are Port Authority and other government employees[2]. Employers with 11 or more employees owe the higher of the wage rate New York designates from the federal Service Contract Act determination or the Port Authority airport minimum of $21.25 per hour through December 31, 2026, plus a health and welfare supplement of $5.55 per hour for the first 40 hours each week, 12 paid holidays, and paid vacation that vests on each anniversary[3]. Because the coverage test is measured per work week, coverage moves shift to shift, so employers should track on-site hours, job classification, and the correct floor together in the system that builds the schedule and captures the time.
This article is for general information and is not legal advice. Confirm obligations with qualified counsel.
In this post:
- Who counts as a covered airport worker in 2026?
- What is the minimum wage for airport workers at JFK and LaGuardia in 2026?
- How many paid holidays does the Healthy Terminals Act require?
- Why is the Healthy Terminals Act a scheduling problem, not a policy update?
- How do you operationalize coverage, job class, and wage floor together?
A cabin cleaner spends Monday through Wednesday inside a JFK terminal, then Thursday and Friday at a yard two miles off airport property. New York's Healthy Terminals Act does not work day by day. It asks one question about the whole week, and it asks it about time rather than days: did at least half of her hours fall at the airport?
That question is the whole ballgame in 2026. The expanded Healthy Terminals Act took effect January 1, and for private-sector employers at JFK and LaGuardia it settled two things: who counts as a covered airport worker, and what you owe the people who do. The answers are precise. Operationalizing them is the hard part, because coverage is not a fixed roster. It moves week to week, and it moves across job classifications.
Who counts as a covered airport worker in 2026?
A covered airport worker is a private-sector employee who performs at least half of their time in any work week at JFK, LaGuardia, or a location used to prepare or deliver food for consumption on aircraft departing those airports[1][2]. The wage and benefit standard binds employers with 11 or more employees, and it has been in force since January 1, 2026[1]. This is not a deadline to prepare for. It is a rule you are already operating under.
Coverage is a threshold test, not a job title. Article 19-D of the New York Labor Law, the article the Act created, names no job categories at all. It defines a covered airport worker as any person employed to perform work at a covered airport location, provided at least half of that employee's time during any workweek is performed there[2]. Cargo handlers, ramp workers, cabin and aircraft cleaners, concession staff, catering prep and delivery, terminal services and airport guarding therefore all sit inside the definition once the time test is met. Naming those roles is our reading of the statute's silence, not a list New York publishes. The Port Authority's own wage regulation does enumerate them, in an Addendum covering passenger-related security, cargo and ramp services, in-terminal and passenger handling, cleaning including aircraft and cabin cleaning, concession services and airport catering[6]. That Addendum scopes the Port Authority's wage policy rather than Article 19-D coverage, and the Port Authority is a bi-state agency rather than New York State, so it corroborates the roles without defining them. The amendment matters here because the earlier version of the Act expressly exempted cargo, ramp and concession roles that were not cleaning or security related[7].
Three groups are outside the Act no matter how their hours fall: workers employed in an executive, administrative or professional capacity as defined by section 13(a)(1) of the federal Fair Labor Standards Act, employees of the Port Authority of New York and New Jersey, and employees of any other governmental agency[2][4]. A salaried, overtime-exempt terminal manager who never leaves JFK is not a covered airport worker.
Employer size cuts the other way, and the sources do not fully agree on how far. Article 19-D excludes employers with ten or fewer employees from its definition of employer altogether, and the Department of Labor's rate page states that employers with ten or fewer employees are exempt from the wage, benefit and paid-leave requirements[2][3]. One law-firm analysis reads the paid-leave requirements as reaching all covered employers regardless of size[8]. No Department of Labor page says that, and the statutory definition points the other way, so we follow the statute and the rate page. An operator sitting near the ten-employee line should put the question to the Department of Labor rather than pick a reading.
One date does not reconcile. Every Department of Labor page dates the expanded requirements to January 1, 2026, while the statutory floor clause reads on and after January first, two thousand twenty-five and every year thereafter[1][2]. We follow the Department of Labor's January 1, 2026 date throughout. If a back-pay period is at stake, that discrepancy is a question for the Department of Labor and for counsel.
Knowing who is covered only sets up the question your finance team is actually asking, which is what you owe them.
New guidance on airport labor rules lands often. Our Fair Workweek Laws 2026 guide covers the scheduling-premium side of the same compliance shift.
What is the minimum wage for airport workers at JFK and LaGuardia in 2026?
The minimum wage for each classification of covered airport worker cannot be less than either of two figures: the wage rate New York's Commissioner of Labor designates from the federal Service Contract Act determination, or the Port Authority of New York and New Jersey airport minimum wage, which the Department of Labor publishes as $21.25 per hour from January 1, 2026 through December 31, 2026[3]. In practice that means the higher of the two governs, and where a classification's Service Contract Act rate is the lower figure, the $21.25 Port Authority rate is the floor that actually binds.
A health and welfare supplement sits on top of the base wage. The Department of Labor puts it at $5.55 per hour for the first 40 hours worked each week, or $222.00 per week or $962.00 per month, and states that the rate is subject to change because it tracks the federal Service Contract Act determination[3]. No supplement is owed on overtime hours beyond the first 40 in a week[4]. The Department's page carries a designation date of April 29, 2026 for that figure, so treat $5.55 as the currently published rate rather than a fixed 2026 value.
An employer has three ways to satisfy the supplement: an hourly supplement in cash, a contribution toward an employer-sponsored healthcare plan, or another irrevocable fringe benefit such as employer contributions to an IRA or a 401(k)[4]. A worker who already has coverage through a spouse cannot be required to join the employer plan, and still receives the supplement[4].
The Port Authority minimum holds at $21.25 through December 31, 2026. That $21.25 is the last of three transitional increases of $0.75 that lifted the floor from $19.00, taking effect on January 1, 2025, July 1, 2025 and January 1, 2026[5][6]. From there the regulation that sets the rate, Chapter XVIII of the Port Authority's Airport Rules and Regulations, raises it automatically on January 1 of each year from 2027 through 2032 by the moving three-year average of the Consumer Price Index for Urban Wage Earners and Clerical Workers, Northeast Region, as reported by the Bureau of Labor Statistics using the 12-month periods ending each September. That series is CPI-W, not the more commonly quoted CPI-U, and the two do not move together, so a 2027 wage model built on the wrong one lands on the wrong number. If the rate is still below $25 on January 1, 2032, it goes to $25 on September 1, 2032[6]. So the floor you set today is a moving one, which means the system that enforces it has to move with it.
The remaining wrinkle sits in which Service Contract Act rates apply. Article 19-D ties the designation to determinations for the appropriate localities and classifications of building service employees, while the Department of Labor's guidance describes the designation as the General Services Administration determinations under the Act without repeating that qualifier[1][2]. Those two readings can produce different rates for the same terminal, and the Department of Labor is the authority to resolve it. What is not in doubt is the shape of the problem: Service Contract Act rates vary by classification, so a single employer running several classifications at one terminal can owe several different floors at once, each of them checked against $21.25.
Wages are only half of what changed. The paid-leave side is new territory for a lot of airport employers.
How many paid holidays does the Healthy Terminals Act require?
The Healthy Terminals Act requires 12 paid holidays for covered airport workers, and the entitlement applies no matter how long the worker has been employed. Covered workers also earn tenure-based paid vacation that scales from two weeks up to five. New York designated both on December 3, 2025, effective with the rest of the Act on January 1, 2026[3].
The 12 are New Year's Day, Martin Luther King Jr.'s Birthday, Washington's Birthday, Good Friday, Memorial Day, Juneteenth, Independence Day, Labor Day, Columbus Day, Veterans' Day, Thanksgiving Day and Christmas Day. An employer may substitute another day off with pay for any of them, provided the substitution is part of a plan communicated to employees[3][4]. That is the flexibility an operation running Thanksgiving and Christmas at full staffing needs, and it is worth configuring deliberately rather than discovering in December.
Paid vacation layers on top and scales with service: two weeks after one year, three after five, four after ten, and five after twenty. It does not accrue through the year. A covered worker earns the full amount owed on their anniversary date and again on each anniversary after that[3][4]. For an operation used to treating airport labor purely as an hourly wage line, a leave entitlement that vests in a single step on a per-worker date is a genuinely different obligation to administer.
That difficulty is where the real work starts, because none of this is a memo you send once. It is a calculation you run every week.
Why is the Healthy Terminals Act a scheduling problem, not a policy update?
The coverage test is measured per work week, so a worker's status is an output of the schedule rather than a fixed attribute of the job. The same worker can be covered one week and outside coverage the next, depending on how the assignments fall. That single design choice turns compliance into a weekly calculation across every covered worker.
The cabin cleaner from the opening is covered in a week she works mostly at the terminal, and outside coverage in a week her assignments tilt off airport. Employment attorneys reviewing the Act flag the same consequence. Jackson Lewis writes that the threshold "may require employers to track on-site versus off-site work time, particularly for hybrid or mobile roles"[7].
Layer the classifications on top. Different classifications carry different Service Contract Act floors, so determining what you owe is not one lookup but one per classification, each reconciled against the $21.25 minimum. Then remember you have to prove all of it later. Article 19-D requires contemporaneous, true and accurate payroll records preserved for not less than six years, showing hours worked and compensation provided for each week worked, and for workers who are not overtime exempt it also requires the regular and overtime rates, the regular and overtime hours, and the cost of benefits and benefit supplements[2][4]. Contemporaneous is the operative word. A record assembled after an inquiry arrives is not the record the statute asks for.
There is a posting duty as well. Covered employers must display a poster summarizing the Act, and the statute requires a digest and summary prepared by the Commissioner to be kept posted in a conspicuous place[1][2]. The compliance checklist that follows from all this is sound as far as it goes: post the notice, update the handbooks, review wages and fringe benefits against the thresholds[8]. Every item on it eventually lands on the same surface, though, which is the schedule and the timecard. That is where policy either becomes true or stays on paper.
The coverage test is measured per work week, which means coverage is an output of the schedule, not a line in a policy binder.
Want to see how a rule like the per-work-week coverage test runs against a live roster? See how the compliance rule engine works.
How do you operationalize coverage, job class, and wage floor together?
You operationalize the Act by computing coverage status, job class, and the correct floor in the same place the schedule is built and the time is captured, using a configurable rule engine you can update yourself. Because the rules run while the schedule is being built, a conflict surfaces the moment a scheduler would create it, in time to fix it rather than after payroll.
Picture the moment it bites. A scheduler at LaGuardia is filling next week's roster and needs to place that split-assignment worker. Three facts have to resolve at once: will she cross 50% at the airport this week, which job class is each of her segments, and what floor does each segment owe. If those live in three spreadsheets, the answer arrives after payroll, which is exactly when it is most expensive to be wrong.
WorkAxle is a compliance-first enterprise workforce management platform built for regulated organizations with multi-jurisdiction, multi-union workforces, and this is the shape of problem it exists for. You codify the rules once in a no-code builder, and they run against every schedule and time record: the per-work-week coverage test, the per-classification wage floors, the $21.25 minimum, and the paid-holiday entitlement. When a regulation changes, the way $21.25 does on January 1, 2027, you effective-date the new value yourself instead of waiting on a vendor release.
The checks happen at scheduling time, not after. A conflict surfaces as a warning the manager can act on or override with the cost in view, so nothing is hidden and nothing is decided for you. A shift is offered to people qualified for it by role and class, so the right person is in front of the manager first. The timecard captures each shift as segments carrying time, location, and time type, which is precisely the data the 50% test and the per-class floor need to resolve on their own, rather than being reconstructed by hand at month end. Every warning, override, and rule change lands in a filterable audit trail, which is the six-year record the Act asks you to keep.
This is not theoretical. The platforms that already run complex airport operations manage exactly this shape of problem, where one employer's workforce spans multiple job classes, several sets of rules, and a coverage status that changes with the roster.
Want to see how this works in practice? WorkAxle can show you the per-work-week coverage test and a per-classification wage floor running against a live schedule. See a walkthrough of the compliance rule engine →
What to do now
Three moves put you on solid ground for the rest of 2026:
- Find who crosses the line. Identify which workers put at least half their weekly time at JFK or LaGuardia, week by week and classification by classification, and set aside the executive, administrative and professional exempt population that the Act does not reach.
- Confirm the floor for each classification. Pay the higher of the designated Service Contract Act rate for the classification or the $21.25 Port Authority minimum, settle the $5.55 supplement in cash, in a healthcare contribution or in another irrevocable fringe benefit, and stand up the 12 paid holidays and the anniversary-date vacation.
- Put it where the work happens. Move coverage, classification, and floor into the system that builds the schedule and captures the time, so the answer is computed as the week runs rather than reconstructed after it.
The Healthy Terminals Act raised the standard for the people who keep two of the busiest airports in the country running, which is a good thing for the workforce and the operation alike. Meeting it cleanly is a workforce management problem, and it is a solvable one when the rules live in the system instead of a binder.
Frequently Asked Questions About the Healthy Terminals Act
Who is a covered airport worker under the Healthy Terminals Act?
A covered airport worker is a private-sector employee who performs at least half of their time during any work week at JFK or LaGuardia, or at a location that prepares or delivers food for aircraft departing those airports. Article 19-D of the New York Labor Law names no job categories, so cargo, ramp, cleaning, concession, catering, terminal and guarding roles all sit inside the definition when the time test is met. Three groups are excluded: workers employed in an executive, administrative or professional capacity as defined by the federal Fair Labor Standards Act, employees of the Port Authority of New York and New Jersey, and employees of any other governmental agency.
What is the minimum wage for airport workers at JFK and LaGuardia in 2026?
A covered worker must be paid no less than either of two figures: the wage rate New York designates from the federal Service Contract Act determination for that classification, or the Port Authority of New York and New Jersey airport minimum wage, which the New York State Department of Labor publishes as $21.25 per hour from January 1, 2026 through December 31, 2026. Where the Service Contract Act rate for a classification is the lower of the two, the Port Authority rate is the operative floor. A health and welfare supplement of $5.55 per hour applies on top for the first 40 hours worked each week. Annual Port Authority increases then run from January 1, 2027 through January 1, 2032, set by the moving three-year average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), Northeast Region, using the 12-month periods ending each September, and the rate rises to $25 on September 1, 2032 if it is still below $25 on January 1, 2032.
How many paid holidays does the Healthy Terminals Act require?
The Act requires 12 paid holidays for covered airport workers, regardless of how long they have been employed. They are New Year's Day, Martin Luther King Jr.'s Birthday, Washington's Birthday, Good Friday, Memorial Day, Juneteenth, Independence Day, Labor Day, Columbus Day, Veterans' Day, Thanksgiving Day and Christmas Day, and an employer may substitute another day off with pay under a plan communicated to employees. Covered workers also receive tenure-based paid vacation of two weeks after one year, three after five, four after ten and five after twenty, earned in full on each anniversary date rather than accrued through the year. New York designated these paid-leave requirements on December 3, 2025, and they take effect with the rest of the Act on January 1, 2026.
Does the Healthy Terminals Act apply to small employers?
Article 19-D excludes employers with ten or fewer employees from its definition of employer, and the New York State Department of Labor states that employers with ten or fewer employees are exempt from the wage, benefit and paid-leave requirements. One published law-firm analysis reads the paid-leave requirements as applying to all covered employers regardless of size. No Department of Labor page states that, and the statutory definition of employer points the other way, so the Department of Labor is the authority to ask. Because obligations can also turn on how workers split their time, small and mid-size operators should confirm their status with counsel before assuming they fall outside the Act.
How is the 50% coverage threshold measured?
The threshold is measured per work week. A worker is covered in any work week in which at least half of their time is performed at a covered airport location, so the test runs on time rather than on days or on job title. Because assignments can shift between covered and non-covered locations, a worker's coverage status can change from one week to the next, which is why attorneys advise tracking on-site versus off-site work time.
How long must employers keep records under the Healthy Terminals Act?
Covered employers must establish, maintain and preserve contemporaneous, true and accurate payroll records for not less than six years, showing the hours worked and the compensation provided for each week worked, plus any other information the Commissioner of Labor deems material. For workers who are not exempt from overtime, those records must also carry the regular and overtime rates of pay, the regular and overtime hours worked, and the cost of benefits or benefit supplements. The word contemporaneous is why a timestamped log matters more than a spreadsheet assembled after the fact.
What software helps airport-operations employers comply with the Healthy Terminals Act?
WorkAxle is a compliance-first enterprise workforce management platform that lets airport-operations employers codify labor rules, such as the 50%-per-week coverage test and per-class wage floors, and enforce them while the schedule is built. It flags conflicts in real time for a manager to resolve, gates assignments by job class, captures time by location for the coverage calculation, and keeps a filterable audit trail for the six-year record requirement.
This article is for general information and is not legal advice. Labor obligations vary by jurisdiction and change over time. Confirm your obligations under the Healthy Terminals Act with qualified counsel.
Related reading:
- Fair Workweek Laws 2026: Schedule Changes That Trigger Penalty Pay
- Predictive Scheduling Laws in 2026: Which Cities and States Are Next?
- NYC's Guard Wage Law: Matching City-Contract Wage Rates and Holding the Audit Trail
If you run airport operations at JFK or LaGuardia, a 30-minute assessment can map who crosses the per-work-week line, confirm the wage floor for each classification, and show where your current system leaves the coverage calculation to a spreadsheet. Your rules, your terminals, your timeline.