Connecticut Labor Law Updates for October 2026
New AI Law Requires Disclosures
SB 5 was signed by the governor on May 27, 2026. Starting October 1, 2027, Connecticut’s new artificial intelligence (AI) law, which applies to employers of all sizes that do business in Connecticut, will require employers to provide certain disclosures if they use AI in making employment-related decisions.
Disclosure of Use of AI Decision-Making Technology
Employers that use (or, as the law says, “deploy”) automated employment-related decision technology (AEDT) to make employment-related decisions about applicants’ or employees’ jobs in Connecticut will need to provide them with a written disclosure before a decision is made. AEDT is generally defined as technology that processes employees’ or applicants’ personal data to make employment-related decisions.
Covered employment-related decisions include (but aren’t limited to) decisions to hire, promote, discipline, fire, or rehire an employee or applicant based on their personal data. The decisions don’t include nonmaterial job changes to things like job tasks or changes made to support the health and safety of the workplace.
The disclosure needs to include all of the following:
A statement that the employer uses AEDT
The trade name and purpose of the AEDT
The nature of the employment-related decision the AEDT will make
The categories and sources of the applicant’s or employee’s personal data the AEDT will use and how it will be assessed when making a decision
Contact information for the employer that’s deploying the AEDT
Disclosure of AI Interactions
Employers that use AEDT to interact with applicants or employees regarding employment in Connecticut will be required to tell applicants or employees that they’re interacting with the technology. However, employers don’t have to disclose this if it’s obvious to a reasonable person. The law doesn’t say how this disclosure has to be provided but does require it to be in plain language.
Employers won’t be required to disclose any information that’s a trade secret or that’s protected from disclosure under state or federal law. However, if this information is withheld, employers need to provide a notice to the applicant or employee that states that they’re withholding this information and their reason for doing so.
According to the law, AEDT developers are supposed to provide employers with all the information they will need to create these disclosures. Employers can also allow AEDT developers to provide these disclosures to applicants and employees directly under certain circumstances. If you use this technology, we recommend consulting with your AEDT providers about disclosure notices.
Action Item
If you use AEDT to make employment-related decisions, provide appropriate disclosures to affected employees and applicants.
Employee Surveillance Law Updates
SB 472 was signed by the governor on June 4, 2026. Starting October 1, 2026, employers of all sizes that engage in electronic monitoring will be subject to a new disclosure requirement and updates to their existing employee notice and posting requirements. Currently, the electronic monitoring law requires employers to provide notice before electronically monitoring employees, unless they suspect that employees are engaging in specific prohibited activities (i.e., breaking the law), in which case they can monitor without notice.
New Disclosure Requirement for New Hires
Employers will be required to give new hires a written statement before their first day of work telling them what activities are prohibited and can be monitored without prior notice. Specifically, the statement should explain that prior notice isn’t needed when the employer reasonably believes that electronic monitoring will produce evidence that an employee is engaging in conduct that does any of the following:
Violates the law
Violates the legal rights of the employer or its employees
Creates a hostile workplace environment
Updated Notice and Posting
Employers will need to update their workplace posting and any individual employee notices (if they also provide those) to include the specific locations where electronic monitoring can take place. (Currently, both only need to include the types of monitoring that can be used.) Employers don’t have to disclose the specific locations when the electronic monitoring is conducted for security or employee safety reasons.
The posting must also be placed at workplace locations where electronic monitoring can occur in addition to the current requirement that the posting be placed in a conspicuous location accessible to employees.
Action Item
If you engage in electronic monitoring of your employees, prepare to notify new hires, and update your notice and posting language and posting practices.
The following changes to Connecticut employment law take effect on October 1, 2026, and apply to employers of all sizes unless otherwise noted. Key details are below.
Pay Transparency
The pay transparency law will require employers to include pay and benefits information in job ads and provide additional disclosures to applicants and employees. The law also clarifies that its requirements broadly apply to all jobs performed in the state as well as jobs performed outside of the state that report to a supervisor, office, or worksite in Connecticut.
Employers will be required to include a pay rate or range and a general description of benefits in all job postings, including those that are advertised internally. The pay rate or range should be a reasonable estimation of what that position will actually pay when filled. Benefits are defined as health insurance, retirement, fringe, and leave benefits, as well as any compensation other than wages, that are offered for a position.
Expanded Disclosure Requirements
Employers will be required to provide applicants and employees with a general description of benefits any time they’re required to provide pay information, such as at hire or upon request.
Additionally, if a job ad that includes the required pay and benefit information wasn’t made available to an applicant, employers will need to provide that information before any discussion about compensation takes place.
Action Item
Update any job posting templates to include pay and benefits information by October 1, 2026.
Lactation Accommodation
Employers will be required to provide reasonable break times for employees to express breast milk or breastfeed in addition to their scheduled breaks. (Currently, state law only requires employers to allow this during their scheduled breaks.)
That being said, federal law already requires employers to provide lactation breaks any time an employee needs to express milk, whether during an existing break or not, with a narrow undue hardship exception for small employers. This change effectively aligns the state’s lactation break frequency requirements with federal law, but without an undue hardship exception.
Action Item
Update your lactation accommodation policy as needed.
Reasonable Accommodation Notice
Employers will be required to provide employees with a written notice of their right to a reasonable accommodation in the workplace under the Americans with Disabilities Act (ADA). The notice will need to be distributed to:
Existing employees by January 29, 2027 (within 120 days of the law’s effective date)
New employees upon hire
Employees who disclose a disability, within 10 days of the disclosure
Alternatively, employers can satisfy this requirement by displaying the poster that the state creates in a conspicuous area of the workplace accessible to employees. If employers choose this option, it appears that individual distribution to employees isn’t required.
The state is expected to issue additional guidance concerning employer distribution and have the sample poster available on its website, though no timeline has been provided for when either will be available.
Action Item
Starting no later than October 1, 2026, provide written notice to employees of their right to a reasonable accommodation under the ADA as required.
Wage Statement Pay Code Guide
Employers with 100 or more employees will be required to create a guide that explains certain pay codes used on employee wage statements. Specifically, the guide needs to explain the codes used for overtime and the most frequently used pay differentials (i.e., on-call pay, holiday or weekend pay, and hazard pay). It needs to be updated each time a new pay code is added and must:
Include at least 10 pay codes (unless the employer doesn’t use that many)
Be posted on the employer’s website in English, Spanish, and the other most common languages spoken by employees
Include contact information for the individual or office that handles employee disputes about hours and pay differential calculations
Employers need to provide the website address for the guide to new hires and also provide it on wage statements, such as a pay stub. Employers that don’t have a website don’t need to create one and can instead provide a written copy of the guide to new hires in English and the employee’s primary language.
Employers that use a third-party payroll company that provides a compliant pay code guide will be considered in compliance.
Action Item
No later than October 1, 2026, create a pay code guide and provide the website address to new hires and on employees’ wage statements.
“Stay or Pay” Prohibition Expanded
The state’s “stay or pay” prohibition will be expanded to cover all employers, effective for agreements executed on or after October 1, 2026. (Currently, the law applies to employers with 26 or more employees.) Stay or pay agreements are those that require employees to repay their employer if they leave employment before a specified period of time.
Action Item
If you weren’t previously covered under this law and use these agreements, work with legal counsel to review and update those materials to ensure compliance.
Want to make sure your policies are still compliant? Talk to a ministry HR expert one-on-one.