Paid family and medical leave exemption information for multi-entity employers

Employers seeking a Paid Family and Medical Leave (PFML) exemption must apply for an exemption for each entity that has its own federal Employer Identification Number (EIN) and a Massachusetts workforce.

PFML exemptions for businesses with multiple EINs

If your organization includes multiple EINs, you must apply for an exemption for each individual entity separately under each EIN in MassTaxConnect. You can submit the same Massachusetts PFML Confirmation of Insurance form or a Self-Insured Insurance Declaration Document for more than one entity, as long as you attach a document on your organization's letter head including the names and EINs of all the entities and confirm that all entities listed are covered under the paid leave policy or plan. You will need to work with your insurance carrier to complete a Confirmation of Insurance form.

Please note, if you are applying for a self-insured exemption, you can submit one surety bond that covers multiple entities. The surety bond must cover the total workforce count for all entities and list each entity as the principal.  

Example: John’s Cars Inc. (2 MA employees) is a holding company that wholly owns two subsidiaries: John’s Auto LLC (20 MA employees) and John’s Service Center Inc. (30 MA employees). Because each of these entities has its own EIN and its own Massachusetts workforce, the employer must submit a separate exemption application for each of the three entities and upload the required documents for each entity.   

Example: Cape Coffee LLC is a parent company that does not have a Massachusetts workforce. However, it has two separate chain locations: Cape Coffee Yarmouth Inc. and Cape Coffee Provincetown Inc., each with its own EIN. Cape Coffee LLC would not need to submit an exemption application because they do not have a Massachusetts workforce. However, both the Yarmouth and Provincetown locations should each submit their own exemption application under each of their respective EIN’s. 

Additional Resources

PFML Self Insured IDD (revised 3/13/2024)

PFML Self Insured IDD (revised 3/13/2024) (fillable)

Paid Family & Medical Leave Benefits Bond 2021 (revised 6/30/2021)