Connecticut
Connecticut: Legislative Updates
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APPLIES TO As Indicated |
EFFECTIVE As Indicated |
QUESTIONS? Contact HR On-Call |
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Discussion
On May 11, 2026, Connecticut’s governor signed Public Act No. 26-12, An Act Concerning Workforce Development and Working Conditions in the State. The Act combines provisions from dozens of individual bills introduced during the 2026 legislative session and represents the most comprehensive overhaul of Connecticut’s workplace laws in recent years. Key provisions affecting private employers are summarized below.
Job Posting Disclosures. Effective October 1, 2026, all employers, regardless of size, must include the wage or wage range and a general description of benefits in all public and internal job postings. The Act revises the definition of “wage range” to mean a range the employer “sets in good faith,” aligning Connecticut with similar statutes in other jurisdictions. The requirement extends to out-of-state positions that report to a Connecticut-based supervisor, office, or worksite. Employers must also disclose pay and benefits information to current employees and to any applicant to whom a job posting has not been made available. Punitive damages are eliminated, though compensatory damages and attorneys’ fees remain available for violations.
Paycheck Transparency Guide. Also effective October 1, 2026, employers with 100 or more employees must create a plain-language guide explaining pay codes used for overtime and commonly used pay differentials, such as shift differentials, on-call pay, hazard pay, call-back pay, and holiday or weekend pay. The guide must include at least 10 pay codes (if applicable), be posted on the employer’s website in English, Spanish, and any other languages commonly spoken by the workforce, and identify a contact for employee questions about timekeeping and pay calculations. The guide must be updated whenever a new pay code is added. Employers must provide the website address to employees at hire and include it on each pay statement. Employers using third-party payroll services may comply by referring employees to a compliant guide published by that provider.
Employment Promissory Notes. Effective October 1, 2026, Connecticut’s existing prohibition on employment promissory notes, such as agreements requiring employees to repay training costs, sign-on bonuses, or relocation expenses if they leave before a specified period, is extended to all employers regardless of size. The prior law applied only to employers with 26 or more employees. Voluntary repayment agreements and certain enumerated exceptions remain permissible.
Minimum Wage at Cannabis Establishments. Effective October 1, 2026, employers operating cannabis establishments, dispensary facilities, or production facilities may no longer apply a tip credit toward minimum wage obligations. These employers must pay employees at least the full Connecticut minimum wage.
Prevailing Wage Recordkeeping. Effective October 1, 2026, employers working on prevailing wage projects must maintain daily attendance records for all workers on covered job sites, including project name and location, date, worker name and trade license number (if applicable), and arrival and departure times. Those records must be submitted weekly to the contracting agency, and are subject to public disclosure under the Freedom of Information Act.
Disability Accommodation and ADA Notice. Effective October 1, 2026, employers must provide written notice of employees’ right to reasonable accommodation under the Americans with Disabilities Act (ADA) to new employees at the start of employment, to existing employees within 120 days (by January 29, 2027), and to any employee within 10 days of notifying the employer of a disability. Employers may satisfy this requirement by posting a notice created by the labor commissioner in a conspicuous, accessible location. The labor commissioner is authorized to issue additional regulations on the method of noticing.
Lactation Accommodation. Effective October 1, 2026, employers must provide reasonable break time for employees to breastfeed or express milk, not limited to the employee’s regular meal or break periods. This expands Connecticut’s existing lactation accommodation requirements, which previously required only that employers make reasonable efforts to accommodate nursing employees during scheduled breaks.
Workers’ Compensation for Assaulted Health Care Workers and Teachers. Effective October 1, 2026, the Act expands workers’ compensation benefits for health care providers and teachers who are unable to work as a result of a physical or negligent assault in the performance of their duties. These employees are entitled to wage replacement equal to 100% of their average weekly wage, with no cap on the benefit amount, for periods of partial or total incapacity resulting from the assault. Reasonably incurred medical expenses and lost wages due to court appearances related to the assault are also covered, and related absences may not be charged against the employee’s accrued paid time off.
Contractor Liability for Unpaid Wages. Effective January 1, 2027, general contractors will be jointly and severally liable for wages left unpaid by their subcontractors on construction, renovation, or rehabilitation projects in Connecticut. Before bringing a claim against a general contractor, employees must provide 30 days’ written notice, unless the employee has previously raised a violation by the same subcontractor with the general contractor. General contractors may include subcontract provisions authorizing unpaid wages to be satisfied from retainage, but such provisions do not limit employees’ right to bring a claim against the general contractor.
Retention of Service Contract Workers. Effective July 1, 2027, successor employers taking over certain service contracts at covered locations must retain covered service contract employees for at least 90 days, provided each employee worked at least 16 hours per week for at least 60 days during the prior 90-day period. Covered locations include higher education facilities, multifamily residential buildings with 50 or more units, commercial buildings exceeding 75,000 square feet, cultural centers, airports, train stations, shopping malls, and warehouses. Covered employees cannot be terminated during the retention period absent just cause. After the 90-day period, the successor employer must provide each retained employee with a written performance evaluation and, if satisfactory, an offer of continued employment.
Action Items
- Review and update job postings to include required disclosures.
- Begin preparing a paycheck transparency guide, as applicable, in all required languages.
- Review existing promissory note agreements with legal counsel.
- If operating a cannabis establishment, update payroll practices to eliminate tip credits.
- If working on prevailing wage projects, implement daily recordkeeping and weekly reporting procedures.
- Provide required ADA accommodation notices to existing employees by required deadline.
- Update onboarding processes to provide new employees with required ADA accommodation notices.
- Review and update lactation accommodation policies and practices.
- Review workers’ compensation practices for covered employees who are victims of assault, as applicable.
- Review subcontractor agreements with legal counsel, as applicable.
- Review service contract terms with legal counsel, as applicable.
- Have appropriate personnel trained on the new and updated requirements.
Connecticut: New Artificial Intelligence Law
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APPLIES TO All Employers with Employees in CT |
EFFECTIVE As Indicated |
QUESTIONS? Contact HR On-Call |
Quick Look
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Discussion
Connecticut has enacted SB 5, a comprehensive law regulating the use of artificial intelligence in employment decisions. Key provisions take effect October 1, 2026, with a pilot program for independent verification organizations launching July 1, 2027.
Coverage. The law applies to any system that processes personal data and produces outputs, such as predictions, scores, rankings, classifications, or recommendations, that are a “substantial factor” in making or materially influencing an employment decision, including decisions related to hiring, promotion, discipline, and termination. These systems are referred to as Automated Employment-related Decision Technology, or AEDT. Generic software tools such as spreadsheets and word processors, and tools used only incidentally or for descriptive or statistical purposes, are excluded. The definition is focused on predictive AI technologies and the potential for algorithmic bias, though it will likely be read broadly enough to include generative AI where its use could cause discriminatory harm.
Bias Testing. The law amends Connecticut’s existing anti-discrimination framework to expressly provide that the use of an automated system is not a defense to a discrimination claim under state law. However, evidence of bias testing, including the quality, scope, and recency of testing efforts, the results, and how findings were addressed, may be considered by courts or agencies when evaluating liability.
Developer vs. Deployer Obligations. The law divides compliance responsibilities between developers (those who build AEDT) and deployers (employers and other entities that use it). The primary compliance burden falls on deployers. Developers must provide deployers with sufficient information to enable compliance with the law’s requirements, where the technology is marketed or intended to materially influence employment decisions. The law does not specify what types of information developers are required to create, which may create practical challenges if deployers request information that developers have not documented.
Notice and Disclosure Requirements. The law imposes two distinct notice obligations on deployers. First, deployers must inform employees or applicants in plain language when they are interacting with an AEDT in real time. This disclosure is not required where it would be obvious to a reasonable person that the interaction involves an automated system. Second, before any employment decision is made using AEDT output, the deployer must provide the affected individual with a written pre-decision notice disclosing: (1) the fact that an AEDT is being used; (2) the purpose of the technology and the type of employment decision involved; (3) the trade name of the system; (4) the categories of personal data processed and how those data are assessed; (5) the sources of the personal data; and (6) contact information for the deployer. Developers may contractually assume these notice and disclosure obligations on behalf of deployers.
Independent Verification Organizations. Beginning July 1, 2027, the law establishes a pilot program under which the Connecticut Department of Consumer Protection may approve up to five independent verification organizations to assess whether AI systems meet defined risk mitigation and safety standards. These organizations do not confer regulatory approval or create a presumption of compliance. Their assessments may be used as evidence in certain civil cases but do not provide a safe harbor or defense in enforcement actions. The program is set to sunset in 2030 and is designed as a testbed for potential future AI auditing or certification requirements.
Enforcement. Violations are deemed to be unfair or deceptive trade practices under the Connecticut Unfair Trade Practices Act (CUTPA) and are enforceable exclusively by the Connecticut attorney general, meaning there is no private right of action. A temporary cure period through December 31, 2027, may be available at the attorney general’s discretion.
Action Items
- Identify covered AEDT systems currently in use or under consideration for employment-related decisions.
- Implement interaction and pre-decision disclosures and notices, as applicable.
- Review vendor and developer agreements with legal counsel.
- Consider bias testing protocols.
- Review and update internal governance frameworks for AEDT use.
- Monitor regulatory updates from the Connecticut attorney general’s office and Department of Consumer Protection.
- Have appropriate personnel trained on the requirements for AEDT use.
Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2026 ManagEase