The Healthy Terminals Act in 2026: Who's Covered at JFK and LaGuardia, and What You Owe

Last updated: July 2026

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.

A cabin cleaner spends Monday through Wednesday inside a JFK terminal, then Thursday and Friday at a yard two miles off airport property. In those first three days she is covered by New York's Healthy Terminals Act. Whether she is covered for the week depends on a number most schedulers have never had to compute: did she cross 50% of her hours 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 the two things people keep asking about: 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 classes.

Who counts as a covered airport worker in 2026?

A covered airport worker is a private-sector employee who spends at least 50% of their time in any work week at JFK, LaGuardia, or a location that prepares or delivers food for aircraft departing those airports. The employer wage and benefit standard binds companies with 11 or more employees. Everything has been in force since January 1, 2026.

Coverage is a threshold test, not a job title (NY Department of Labor). That is why the definition now reaches classes earlier versions left out. Cargo handlers, ramp workers, cabin and aircraft cleaners, concession staff, catering prep and delivery, terminal services, and airport guarding all fall inside it when the hours line up. The role does not decide coverage. The weekly hours at the airport do.

The wage and benefit standard binds employers with 11 or more employees (NY DOL). Employers with 10 or fewer are exempt from that wage standard. None of this is a deadline to prepare for anymore, because it has applied since January 1, 2026, so it is a rule you are already operating under.

Knowing who is covered only sets up the question your finance team is actually asking, which is what you owe them.

What is the minimum wage for airport workers at JFK and LaGuardia in 2026?

Covered employers must pay the greater of two figures: the federal Service Contract Act rate for the worker's position, or the Port Authority of New York and New Jersey airport minimum wage, which is $21.25 per hour for 2026. A designated health and welfare rate of $5.55 per hour, for up to 40 hours a week, applies on top of the base wage.

Whichever number is higher for a given worker is the one you pay (NY DOL). The Port Authority minimum holds through December 31, 2026, then rises every year starting January 1, 2027, tied to inflation through a Consumer Price Index formula (Port Authority of NY and NJ). So the floor you set today is a moving one, which means the system that enforces it has to move with it.

An employer can satisfy the health and welfare component by paying the supplemental amount or by contributing it to a qualifying health plan. The wrinkle sits in the Service Contract Act rate: it varies by position, so a single employer running several job classes at one terminal can owe several different floors at once.

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. These paid-leave provisions were designated December 3, 2025.

The 12 holidays run from New Year's Day through Christmas (NY DOL). Paid vacation layers on top and scales with service: two weeks after one year, three after five, four after ten, and five after twenty. For an operation used to treating airport labor purely as an hourly wage line, an accruing, tenure-based leave entitlement 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 50% 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. This is why employment attorneys reviewing the Act tell clients to build a way to track it. As Jackson Lewis put it, the threshold "may require employers to track on-site versus off-site work time, particularly for hybrid or mobile roles," and to stand up a system that records those hours (Jackson Lewis).

Layer the job classes on top. Different positions carry different Service Contract Act floors, so determining what you owe is not one lookup but one per class, reconciled against the $21.25 minimum. Then remember you have to prove all of it later, because covered employers must keep payroll records for six years (NY DOL).

The checklist the law firms hand out is sound as far as it goes: post the required notice, update your handbooks, and review your wages and fringe benefits against the new thresholds (Fisher Phillips). 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 50% test is measured per work week, which means coverage is an output of the schedule, not a line in a policy binder.

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 50%-per-week coverage test, the per-class wage floors, the $21.25 minimum, and the paid-holiday entitlement. When a regulation changes, the way $21.25 will in January 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.

What to do now

Three moves put you on solid ground for the rest of 2026:

1. Find who crosses the line. Identify which workers hit 50% of their hours at JFK or LaGuardia by week and by job class, not by title, because coverage follows the hours and not the role.
2. Confirm the floor for each class. For every class, pay the greater of its Service Contract Act rate or the $21.25 Port Authority minimum, add the $5.55 health and welfare rate, and stand up the 12 paid holidays and tenure-based vacation.
3. Put it where the work happens. Move coverage, class, 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 50% 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. Coverage depends on weekly hours at the airport, not on job title. That means cargo, ramp, cleaning, concession, catering, terminal, and guarding roles can all be covered when the hours line up.

What is the minimum wage for airport workers at JFK and LaGuardia in 2026?

Covered employers must pay the greater of the federal Service Contract Act rate for the position or the Port Authority of New York and New Jersey airport minimum wage, which is $21.25 per hour for 2026. A designated health and welfare rate of $5.55 per hour, for up to 40 hours a week, also applies. The Port Authority minimum begins rising annually on January 1, 2027, tied to a Consumer Price Index formula.

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. Covered workers are also entitled to tenure-based paid vacation, which scales from two weeks after one year to five weeks after twenty. These paid-leave provisions were designated December 3, 2025, ahead of the wider January 1, 2026 wage and benefit requirements.

Does the Healthy Terminals Act apply to small employers?

The wage and benefit standard applies to employers with 11 or more employees. Employers with 10 or fewer employees are exempt from that wage standard. Because employer obligations can turn on how you count employees and how workers split their time, small and mid-size operators should confirm their own 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 50% of their time is spent at a covered airport location. 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 hours.

How long must employers keep records under the Healthy Terminals Act?

Covered employers must keep payroll records showing hours and compensation for each week worked, along with other information required under New York labor law, for six years. That obligation is one reason an audit-ready, 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?
• What an audit-ready workforce record actually looks like
  
  

If you run airport operations at JFK or LaGuardia, a 30-minute assessment can map who crosses the 50%-per-week line, confirm the wage floor for each job class, and show where your current system leaves the coverage calculation to a spreadsheet — your rules, your terminals, your timeline.

Schedule a 30-minute assessment →