The mandate table

| Jurisdiction | Effective | Employer threshold | Covered employee | Key rule | |---|---|---|---|---| | New York City | 2016 | 20+ full-time employees in NYC | 30+ hrs/week | Pretax election up to federal limit | | New Jersey (statewide) | 2020 | 20+ employees in NJ | All employees, with limited exemptions | Pretax election up to federal limit | | Washington, D.C. | 2016 | 20+ employees in DC | All employees | Pretax election, employer-paid subsidy, or employer-provided transit | | Philadelphia | Dec 31, 2022 | 50+ covered employees | 30+ hrs/week in Philadelphia, 12+ months | Pretax election or employer-paid direct benefit | | Chicago and Cook County, IL | Jan 1, 2024 | 50+ covered employees within 1 mile of fixed-route transit (six-county RTA region + Bloomington-Normal) | 35+ hrs/week, after 120 days | Pretax transit election up to federal limit | | Seattle | Jan 1, 2020 | 20+ employees worldwide | 10+ hrs/week in Seattle | Pretax election OR employer subsidy up to federal limit | | San Francisco Bay Area (nine counties) | 2014 | 50+ full-time employees | 20+ hrs/week | One of: pretax election, employer subsidy, employer transit, or alternative commuter benefit | | Berkeley, CA (TRACC) | 2017 | 10+ employees averaging 10+ hrs/week | All employees | One of: pretax, employer-paid transit/vanpool/bike, or employer shuttle | | Los Angeles area (SCAQMD Rule 2202) | 1995 (amended) | 250+ employees at a worksite | All employees | Choose from emission-reduction strategy menu, including pretax | | Hawaii (state-enabling) | 2018 | Counties may set ordinance for 20+ employees | Per county | Pretax election up to federal limit, or employer subsidy |

What the limits are in 2026

  • $340 per month for transit and vanpool (IRC §132(f), as adjusted by IRS Rev. Proc. 2025-32)
  • $340 per month for qualified parking (parking garages, parking lots, parking meters, parking apps)

What "covered" means in plain language

If you are reading this and asking "does my business have to do this?" the short answer is: yes if you have 20 or more employees working in NYC, NJ, DC, or Seattle; yes if you have 50 or more in Philadelphia, the Bay Area, or near transit in the Illinois RTA region; yes if you have 10 or more in Berkeley; yes if you have 250 or more at a single LA-area worksite. If you are not in one of these places, you are not required, but most employers still offer the benefit because both the employer (FICA) and the employee (income tax + FICA) save when employees run commuter spend pretax.

State preemption

Several states (Alabama, Arkansas, Florida, Georgia, Indiana, Iowa, Kansas, Michigan, Missouri, North Carolina, South Carolina, Texas, Wisconsin) have preemption laws that block cities from passing their own commuter benefit mandates. Employers in those states have no local mandate, but the federal pretax option is still available.

What Alice does

Alice runs the program end to end, with connections to ADP, UKG, Paylocity, Paycom, Paychex, Toast, Workday, and 25+ others. No up-front employer cost. No manual open enrollment to manage. No employee pre-funding required and only a small reserve deposit from the employer.

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