What is the Minimum Wage Ordinance?

The Minimum Wage Ordinance sets the lowest hourly pay rate for work done in the City of Saint Paul. Minimum Wage requirements vary based on a business's size. The City will require businesses of all sizes to pay their employees a minimum wage of $15 an hour by 2027.

  • 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. 
  • Employers must keep track of where their employees are working. Records can include (but are not limited to) delivery addresses, estimated travel times, historical averages, dispatch logs, scheduling logs, and appointment details. 
  • Looking for information in Hmong? Watch this Hmong-language video created in partnership with 3HmongTV and Councilmember Nelsie Yang.

Contractors and subcontractors performing work for the City may be required to pay their workers the City's Prevailing Wage or Living Wage

Minimum Wage Ordinance Prevailing Wage and Living Wage Ordinances

Who does the ordinance cover?

The ordinance covers all employees performing work in the City of Saint Paul. Employees must perform at least two hours of work in Saint Paul in one week to be owed the minimum wage. 

  • Full-time, part-time, temporary, and paid on-call employees are all covered under the ordinance. 
  • Immigration status does not impact coverage of the Minimum Wage Ordinance. The City's Department of Human Rights and Equal Economic Opportunity (HREEO) enforces the Minimum Wage ordinance. HREEO does not ask for an employee’s immigration status when an employee reaches out with a question or files a complaint. It is illegal for an employer to suggest that they will report immigration status if an employee complains.
  • The ordinance does not cover independent contractors or individuals in the Minnesota Extended Employment Program. It also does not cover people with disabilities who receive licensed home- and community-based services, if their employment receives intensive support services.

Minimum Wage Administrative Rules

The Labor Standards Division created the Administrative Rules to show how the Minimum Wage Ordinance applies to both employers and employees. 

What is the Minimum Wage in Saint Paul?

How to Calculate Your Business Size

Count all full-time, part-time, joint, and temporary employees. Include employees not located in Saint Paul (unless you are a restaurant with fewer than 10 locations, see below). 

Generally, business size is based on the average number of employees per week during the previous calendar year. Owners and board members are not counted as employees when calculating business size. Employers may not mask employees with titles to change their business size.

New Business

If you've been in business less than one year, you're considered a new business. To determine business size for new businesses, calculate your average number of employees for the first 13 weeks you were in business. To do this, add the total number of employees per week for the first 13 weeks and then divide that total number by 13. Please reach out to the Department if you have any questions. 

Joint Venture

Integrated enterprises (or joint ventures) count as one employer under the ordinance. When calculating your business size, add the employees from all businesses involved in the joint venture. Be sure to count joint employees only once. 

The Labor Standards Division will determine the existence of an integrated enterprise by assessing the degree of control exercised by one entity over the operation of another entity. The factors in this assessment include, but are not limited to:

  • Degree of interrelation between the operations;
  • Degree to which the entities share common management;
  • Centralized control of labor relations;
  • Degree of common ownership or financial control over the entities.


If you operate a franchise, calculate the total number of employees at all franchise locations owned and operated by a single franchisee. Please reach out to the Department if you have any questions. 

Franchise relationships with more than two parties are considered integrated enterprises and must count employees of all sub franchises. The burden is on you as an employer to establish you are not an integrated enterprise if you disagree with this classification.


Full-service restaurants located in Saint Paul with fewer than 10 locations nationwide are considered unique employers when determining business size (except franchises). To calculate your business size, add the number of employees from each location separately per week for 52 weeks and divide by 52. 

If there is only one location in Saint Paul, you only need to count employees from that one location. You do not need to count employees from other locations outside of Saint Paul (as long as your restaurant has fewer than 10 total locations).

Frequently Asked Questions

Last Edited: June 24, 2024