Beginning October 1, 2026, Manitoba employers will face new restrictions on when they can require employees to provide sick notes for short-term absences.
The changes are part of Manitoba’s effort to reduce unnecessary medical appointments while encouraging employers to adopt more effective approaches to managing employee attendance.
For employers, this change is about more than removing a requirement from an employee handbook. Organizations should review their sick leave, attendance management and medical documentation practices to ensure they are prepared for the new rules.
What Is Changing in Manitoba?
Under Manitoba’s amended Employment Standards Code, employers will generally not be permitted to require a sick note when an employee is absent because of illness or injury if:
- the absence lasts one week or less; or
- the employee has been absent for 10 scheduled workdays or less due to illness or injury during the same calendar year.
Once the applicable threshold has been exceeded, an employer may be permitted to request a sick note.
The legislation also provides that an absence for part of a scheduled workday can count as a day of absence when determining the annual threshold.
These restrictions take effect on October 1, 2026.
Sick Notes Are Not the Same as Other Medical Documentation
Employers should understand that the new restrictions do not eliminate the ability to request medical documentation in every situation.
A sick note generally verifies that an employee cannot or should not attend work for a short period because of an illness or injury.
Other forms of medical documentation can serve a much broader purpose.
For example, medical information may still be required in circumstances involving certain protected leaves, workplace accommodations, longer-term illnesses or injuries, disability matters, or determining whether an employee is medically fit to return to work.
Employers should therefore avoid treating all medical documentation as a “sick note.” The purpose for requesting the information matters.
Why Is Manitoba Restricting Sick Notes?
For many years, requiring a doctor’s note was a common way for employers to verify short-term illness. However, requiring an employee with a minor illness to visit a healthcare professional does not necessarily provide an employer with meaningful additional information.
Consider an employee who misses two days of work because of flu symptoms. By the time the employee is able to see a healthcare professional, those symptoms may have improved or disappeared. The healthcare professional may therefore have to rely largely on what the employee reports about their earlier symptoms.
There can also be unintended consequences.
An employee who would otherwise stay home and recover may instead have to travel to a clinic and wait for an appointment simply to obtain documentation. Another employee may decide that getting a sick note is too inconvenient and report to work while ill, potentially exposing coworkers.
Reducing unnecessary appointments can also allow healthcare professionals to dedicate more time to patients who require medical assessment and treatment.
For employers, the upcoming change presents an opportunity to reconsider whether a sick note is actually the most effective way to manage short-term absenteeism.
Culpable and Non-Culpable Absenteeism
Removing sick notes does not mean employers have to ignore attendance problems.
A critical part of attendance management is understanding the difference between culpable and non-culpable absenteeism.
Culpable absenteeism generally involves behaviour within an employee’s control. Examples could include repeated lateness without a legitimate explanation, failing to follow established attendance procedures, or misrepresenting the reason for an absence.
Depending on the circumstances, these situations may warrant coaching, performance management, progressive discipline or other corrective measures.
Non-culpable absenteeism involves legitimate absences outside the employee’s control, such as illness, injury or disability.
These circumstances require a different approach. Employers may need to consider accommodation obligations, appropriate medical information, protected leave requirements and other employment standards or human rights considerations.
An effective attendance management strategy recognizes this distinction rather than treating every absence as employee misconduct.
What Can Employers Use Instead of Sick Notes?
Employers still have several tools available to manage attendance effectively.
Establish Clear Attendance Expectations
Employees should understand how and when they are expected to notify their employer that they will be absent.
A sick leave or attendance policy should address matters such as:
- who an employee should contact;
- acceptable methods of notification;
- when notification must be provided;
- how absences are recorded;
- whether sick time is paid or unpaid; and
- responsibilities for both employees and managers.
Clear expectations help reduce confusion and allow policies to be applied more consistently.
Consider Employee Self-Attestation
For short-term absences, employers may consider allowing employees to complete a self-attestation confirming that they were unable to work because of illness or injury.
This provides the organization with a record of the absence without requiring the employee to make an unnecessary medical appointment.
It can also establish documentation that can be reviewed later if questions about an employee’s attendance arise.
Monitor Attendance Patterns
Employers do not need a doctor’s note for every absence to identify potential attendance concerns.
HR information systems, payroll records and regular attendance reviews can help organizations identify unusual or recurring patterns.
For example, consistently missing scheduled shifts immediately before or after weekends or holidays may warrant a conversation with the employee.
The important distinction is between identifying a pattern that requires further review and automatically assuming that an employee is abusing sick leave.
Address Concerns Directly
When an attendance pattern raises legitimate concerns, managers should address the issue with the employee rather than relying exclusively on medical notes.
A discussion may reveal an attendance problem that needs to be corrected, or it may uncover a health-related issue that requires a completely different response, such as workplace accommodation.
Managers should be trained to approach these conversations consistently and appropriately.
Building Trust Without Losing Accountability
Some employers may worry that restricting sick notes will make it more difficult to manage absenteeism.
However, trust and accountability do not have to conflict.
Organizations can establish clear expectations, document absences, monitor attendance trends and address suspected misuse while still recognizing that employees occasionally become sick and need time to recover.
A workplace where employees feel they can legitimately take a sick day without unnecessary barriers can also help prevent employees from reporting to work while ill.
At the same time, consistent attendance procedures ensure employees understand that attendance remains an important workplace responsibility.
What Manitoba Employers Should Do Before October 1
With the new requirements approaching, employers should review their existing policies and procedures now.
Organizations should consider:
- Reviewing employment policies and handbooks for language requiring doctor’s notes for short-term absences.
- Updating sick leave and attendance policies to reflect the new restrictions.
- Reviewing employment agreements and internal procedures that reference medical documentation.
- Establishing alternatives, such as employee self-attestation for short-term illness.
- Training managers and supervisors on when medical documentation can and cannot be requested.
- Creating consistent attendance tracking procedures to identify patterns without unnecessarily requesting medical information.
- Communicating changes to employees before the new requirements take effect.
Organizations with unionized employees should also consider applicable collective agreement provisions when reviewing their practices.
When Can an Employer Still Require a Sick Note?
The new rules do not prohibit sick notes entirely.
Under the amended Employment Standards Code, an employer may require a sick note where an employee’s illness or injury-related absence continues for more than one week or where the employee has been absent because of illness or injury on more than 10 scheduled workdays in the calendar year.
When an employer requires a sick note under the legislation, additional requirements apply, including rules regarding the healthcare professionals from whom documentation may be obtained and reimbursement of reasonable costs associated with obtaining the note.
Employers should also remember that separate rules apply to medical documentation used for purposes such as certain protected leaves and determining fitness to return to work.
Preparing Your Workplace for the Change
Manitoba’s new sick note restrictions represent a shift in how employers are expected to approach short-term illness and attendance management.
For organizations, simply removing “doctor’s note required” from a policy may not be enough.
This is an opportunity to build a more structured approach to attendance that combines clear expectations, appropriate documentation, consistent management practices and trust between employees and employers.
StratHR Solutions can help your organization review and update its sick leave, attendance management and workplace policies in preparation for Manitoba’s new requirements.
From policy development and HR compliance reviews to manager training and ongoing HR support, our team can help ensure your organization is prepared for the changes taking effect October 1, 2026.
Need support updating your workplace policies? Contact StratHR Solutions to get started.
This article provides general HR information and should not be considered legal advice. Employment standards and other workplace requirements can vary depending on the organization and circumstances.
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