Connecticut employers have two implementation dates to keep separate. The first is October 1, 2026, when Public Act 26-15 changes how automated employment technology fits into specified state discrimination claims and adds a technology-related disclosure to notices an employer already gives the Connecticut Labor Department under the federal Worker Adjustment and Retraining Notification Act. The second is October 1, 2027, when the act's operational duties for defined automated employment-related decision technology begin applying to qualifying deployments.

The distinction matters because Connecticut did not enact every workplace-AI proposal considered in 2026. A separate bill, SB 435, proposed bias audits, human review, data correction, post-decision explanations, recordkeeping, and a civil action. That bill did not become law. Public Act 26-15 is narrower: it emphasizes pre-decision notice, disclosure when an employee or applicant interacts with covered technology, developer-to-deployer information, existing civil-rights law, and a limited addition to WARN reporting.

This guide summarizes the enacted text and official Connecticut materials as verified on September 22, 2026. It is general regulatory information, not individualized legal advice.

What Connecticut enacted

Governor Ned Lamont signed Senate Bill 5 as Public Act 26-15 on May 27, 2026. The 74-page act covers online safety, artificial intelligence, workforce development, state-government systems, and other subjects. The employment provisions most relevant to private employers appear in sections 7 through 14 and section 26. Section 29 separately directs a University of Connecticut institute to study AI's workforce effects; that study mandate is not an employer compliance duty.

Sections 7–12 define automated employment-related decision technology and assign information and disclosure duties to developers and deployers. Sections 13–14 amend Connecticut's employment-discrimination statutes. Section 26 adds a question about AI or technological change to certain layoff notices. These provisions sit inside one public act, but their triggers, regulated parties, enforcement mechanisms, and practical dates are not identical.

What changes first: October 1, 2026

Public Act 26-15 amends Connecticut General Statutes section 46a-60, the state's principal employment-discrimination provision, and section 46a-81c, which addresses sexual-orientation discrimination in employment. In the covered actions, use of automated employment-related decision technology is not a defense to a discrimination complaint. The commission or court may consider evidence of anti-bias testing or similar proactive efforts, including the quality, effectiveness, recency, scope, results, and response to that work.

That language does not make testing a complete defense, create a universal statutory bias-audit schedule, or declare every use unlawful. It confirms that an employer cannot answer an otherwise supported discrimination claim simply by pointing to the technology. Evidence of testing may be considered, but the statute does not say it automatically defeats liability.

The October 1 amendments are also distinct from the Attorney General's February 2026 AI memorandum. That earlier guidance said existing anti-discrimination laws apply to algorithmic discrimination as they apply to other discriminatory conduct, including in hiring and employment. The memorandum expressly describes itself as nonbinding and nonprecedential. Public Act 26-15 subsequently added technology-specific language to the statutes themselves.

The AI-related layoff and WARN provision

Section 26 creates a targeted disclosure rather than a new state layoff-notice regime. Effective October 1, 2026, each employer that serves written notice on the Connecticut Labor Department under 29 U.S.C. § 2102(a)—the federal WARN Act notice provision—must also tell the department whether the layoffs covered by that notice relate to the employer's use of artificial intelligence or another technological change. The disclosure must use the form and manner prescribed by the Labor Commissioner.

The act does not state a separate penalty within section 26. Employers evaluating a planned closing or mass layoff still need to determine federal WARN coverage under the federal statute and any other applicable law. If the cited federal notice is required and served on the Connecticut Labor Department, the new Connecticut disclosure becomes relevant.

What changes later: qualifying deployments on or after October 1, 2027

Sections 7–12 are labeled effective October 1, 2026, but the principal duties in sections 8, 9, and 10 use a later trigger: a developer or deployer acting on or after October 1, 2027. The safest operational reading is therefore to preserve both dates. The sections become effective in October 2026, while the specified duties apply to qualifying deployments beginning October 1, 2027.

An automated employment-related decision technology is technology that processes personal data and uses computation to generate an output—such as a prediction, recommendation, classification, ranking, or score—that is a substantial factor used to make or materially influence an employment-related decision. A substantial factor includes an output that meaningfully alters the result. The definition is functional: the question is not merely whether a product is described as AI, but whether its computational output plays that role in a covered decision.

Employment-related decisions include decisions based on an individual's personal data to hire, promote, discipline, discharge, renew employment, select the individual for training or apprenticeship, or determine tenure, terms, privileges, or conditions of employment. The definition excludes a nonmaterial change in job tasks, responsibilities, hours, or assignments. It also excludes decisions concerning workplace health and safety, scheduling and planning, or productivity monitoring.

Which businesses, employees, and applicants are covered

A deployer is a person doing business in Connecticut that puts covered technology into use in the state. A developer is a person doing business in the state that develops or intentionally and substantially modifies the technology. The covered employment decision must concern an individual in Connecticut, and the interaction rule addresses an employee or applicant for employment in the state.

The developer-information duty is limited to technology advertised, marketed, configured, contracted for, sold, or licensed for use in materially influencing an employment-related decision. A developer and deployer may enter a binding contract under which the developer assumes identified deployer duties under sections 9 and 10. That allocation must be clearly stated; the statutory option is not a reason to leave operational responsibility uncertain.

The act excludes listed common tools—including word processing, spreadsheets, hosting, storage, cybersecurity, filtering, calculators, and database software—when they do not make or materially influence an employment decision. It also excludes systems or services used only incidentally and information that is purely descriptive, diagnostic, or statistical and is not relied upon to make or materially influence the decision.

The 2027 notices and disclosures

  1. Developer information: for covered technology deployed in Connecticut on or after October 1, 2027, the developer must provide the deployer the information needed to perform the duties in sections 9 and 10, subject to the marketed-use limitation and contractual-allocation option.
  2. Interaction disclosure: when covered technology is intended to interact with a Connecticut employee or applicant, the deployer must disclose in plain language that the person is interacting with the technology. No disclosure is required when a reasonable person would consider the interaction obvious.
  3. Pre-decision written notice: before a covered employment decision, the deployer must identify that it deployed the technology; its purpose and the nature of the decision; the technology's trade name; the categories of personal data it will analyze or process and how that data will be assessed; the sources of that data; and deployer contact information.
  4. Protected information: sections 8–10 do not require disclosure of trade secrets or information otherwise protected under state or federal law. A person relying on that protection must notify the person from whom information is withheld and state the basis.

Enforcement

A violation of sections 8–11 is an unfair or deceptive trade practice enforced solely by the Connecticut Attorney General. For a violation occurring on or before December 31, 2027, the Attorney General may issue a notice of violation and provide 60 days to cure when the Attorney General determines that a cure is possible. The word “may” matters: the statute does not promise every respondent a cure notice.

The act says the private-action provision in Connecticut General Statutes section 42-110g does not apply to these violations and that sections 8–12 do not create a private right of action. That limit is specific to this statutory framework. It does not erase claims or enforcement under the amended civil-rights statutes or other applicable law.

Enacted law, official guidance, and the proposal that failed

Three source categories should remain separate. Public Act 26-15 is enacted law. The Attorney General memorandum is official but nonbinding guidance about existing law. SB 435 is a failed 2026 proposal. The official SB 435 history ends with an April 20 favorable report and Senate calendar placement; Connecticut's regular session adjourned May 6 without enactment.

SB 435 would have imposed a materially broader program, including bias audits, human review, appeal and data-correction mechanisms, records, collective-bargaining provisions, and a civil action. None of those proposed duties should be imported into Public Act 26-15. The enacted act does, however, leave employers subject to existing anti-discrimination law and expressly adds the provisions described above.

What employers should prepare now

  1. Separate the dates. Prepare October 2026 processes for discrimination risk and any federal-WARN-related notice, while building the covered-technology notice workflow for October 2027.
  2. Inventory decision tools by function. Identify systems used in hiring, promotion, discipline, discharge, renewal, training selection, and employment terms, then document whether their outputs meaningfully change an outcome.
  3. Map Connecticut scope. Record whether the business deploys the technology in Connecticut and whether a decision or interaction concerns a Connecticut employee or applicant.
  4. Review discrimination controls. Test and monitor for unlawful outcomes as appropriate, but do not describe testing as an automatic statutory defense or confuse it with the independent audit regime proposed in SB 435.
  5. Prepare the WARN data point. If the organization may serve a federal WARN notice on the Connecticut Labor Department, determine who can document whether the covered layoffs relate to AI or another technological change and monitor the department's prescribed form and process.
  6. Build 2027 notices from the enacted fields. Capture the technology's trade name, purpose, decision type, personal-data categories, assessment method, data sources, and deployer contact information.
  7. Address interactive systems. Decide how covered chatbots or other interactive employment technology will provide a plain-language disclosure and when the reasonable-person obviousness exception is supportable.
  8. Strengthen vendor terms. Require enough information to issue the statutory notices, identify intended employment uses and material modifications, and specify whether the developer has contractually assumed any deployer duties.
  9. Maintain source discipline. Track Attorney General and Labor Department materials, but distinguish later guidance or forms from the enacted text and confirm whether any legislative amendment changes the dates or scope.

Timeline

DateDevelopmentEmployer significance
February 25, 2026Attorney General issued AI memorandumNonbinding guidance explained how existing laws may apply to AI, including employment uses.
May 6, 2026Regular legislative session adjournedSB 435 did not become law; its broader proposed duties are not operative.
May 27, 2026Governor signed Public Act 26-15The enacted act established the relevant 2026 and 2027 framework.
October 1, 2026Sections 7–14 and 26 effectiveDiscrimination amendments and the federal-WARN-related disclosure take effect; sections 7–12 enter law with later operational triggers in sections 8–10.
October 1, 2027Deployment trigger in sections 8–10Developer information, interaction disclosure, and pre-decision notice duties begin for qualifying deployments on or after this date.
December 31, 2027End of violations eligible for temporary cure provisionOnly violations occurring on or before this date fall within section 12's discretionary 60-day cure language.

Bottom line

Connecticut's enacted approach is narrower than several 2026 proposals but operationally important. In October 2026, employers face new technology-specific language within state discrimination law and an additional disclosure when an existing federal WARN notice is served on the state. In October 2027, qualifying deployments of automated employment-related decision technology bring developer-information, interaction-disclosure, and pre-decision-notice duties.

The immediate compliance task is classification: identify what is enacted, what is future-triggered, what is nonbinding guidance, and what never passed. From there, employers can build notices and vendor documentation around the actual statutory fields without importing bias-audit, appeal, or human-review requirements from SB 435.

Primary sources and related coverage