Connecticut Employers Face New Pay, AI, and Accommodation Rules in 2026-27
Connecticut has enacted four major employment law changes that will reshape how employers handle pay disclosure, artificial intelligence hiring decisions, and workplace accommodations. Three take effect October 1, 2026. A fourth, regulating AI in employment decisions, takes effect October 1, 2027.
Pay Transparency and Pay Code Guides
Starting October 1, 2026, all Connecticut employers must include wage ranges and a general description of benefits in job postings, whether internal or external.
Employers with at least 100 employees face a more demanding requirement: creating a multilingual employee guide for pay codes. The guide must cover at least 10 pay codes for overtime and common differentials such as shift pay, on-call pay, hazard pay, and holiday pay.
The guide must be posted in English, Spanish, and other languages commonly spoken by the employer's workforce. It should include contact information for employees who dispute pay calculations. Employers without an internal website may provide a written copy to employees upon hire in English and the employee's primary language.
Third-party payroll providers can satisfy this requirement by publishing a compliant guide that employers reference to their workers.
Employment Promissory Notes Banned Across All Employers
Connecticut previously prohibited employment promissory notes only for employers with 26 or more employees. The new law extends the ban to all employers effective October 1, 2026.
An employment promissory note requires an employee to pay the employer if they leave before a stated period ends. This includes agreements framed as reimbursement for training. Any such agreement executed after October 1, 2026, as a condition of employment is void and against public policy.
Four exceptions remain valid: requiring repayment of sums advanced to the employee, payment for property sold or leased to the employee, compliance with sabbatical terms for educational personnel, and promissory notes agreed to by the employer and a collective bargaining representative.
Workplace Accommodation Notices Required
Employers must notify workers of their right to reasonable accommodation for disabilities under the Americans with Disabilities Act. This requirement takes effect October 1, 2026.
Employers must provide written notice to new employees at hire, existing employees within 120 days of October 1, 2026 (by January 29, 2027), and any employee who discloses a disability within 10 days of that disclosure.
Compliance can be satisfied by displaying a poster created by Connecticut's labor commissioner in a conspicuous, accessible place at the workplace. The labor commissioner may adopt additional regulations on how employers must provide this notice.
Lactation Break Requirements Expanded
Connecticut law now mandates reasonable break times for employees to breastfeed or express breast milk for a nursing child, effective October 1, 2026. This expands prior law, which allowed employees to breastfeed during scheduled breaks.
Employers should also review obligations under the federal PUMP for Nursing Mothers Act and Pregnant Workers Fairness Act.
AI in Employment Decisions Faces New Restrictions
Connecticut's Artificial Intelligence Responsibility and Transparency Act regulates how employers use automated systems to make hiring and employment decisions. The law takes effect October 1, 2027.
Employers deploying automated employment-related decision processes must notify employees and applicants before the system is used. The notice must explain that an automated process is being used, its purpose, how to opt out, and how to contact the employer.
If the system makes an adverse decision against an employee or applicant, the employer must provide a high-level statement of reasons and give the individual an opportunity to examine and correct personal data used in the decision that was not provided by that person.
Developers of these systems must provide employers with the tools needed to meet these disclosure obligations. The law does not require disclosure of trade secrets.
A separate provision, effective October 1, 2026, makes it a violation of Connecticut's Fair Employment Practices Act to use automated employment technology in a way that causes an adverse decision based on protected status. Using such technology is not a defense against discrimination complaints. Courts and the Commission on Human Rights and Opportunities may consider evidence of anti-bias testing or other proactive efforts to prevent discrimination.
The law also prohibits AI technology from modifying collective bargaining agreements, impairing a union's role as exclusive representative, or altering the employer-employee organization relationship. These union-specific provisions take effect October 1, 2026.
Legal teams should begin reviewing these requirements now. Compliance deadlines begin in six months.
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