Connecticut Employers Face New AI Disclosure Rules Starting 2026

Connecticut employers using artificial intelligence to screen, rank, or evaluate workers must disclose those practices in writing under a new law signed May 27, 2026, by Governor Ned Lamont.

The Connecticut Artificial Intelligence Responsibility and Transparency Act (Public Act 26-15 / SB 5) takes effect October 1, 2026, with specific disclosure obligations kicking in a year later. The statute targets "automated employment-related decision technology" (AEDT) — systems that process personal data to generate outputs, predictions, rankings, recommendations, or scores that substantially influence hiring, promotion, discipline, or discharge decisions.

What Employers Must Disclose

Starting October 1, 2027, employers must provide written notice to employees and job applicants whenever AEDT is used. The notice must identify the technology's trade name, explain its purpose, and list the categories of personal data analyzed. The requirement shifts the transparency burden onto employers and AI vendors, forcing them to document how automated decisions are reached rather than shielding behind proprietary algorithms.

No 'Black Box' Defense

The law closes a loophole that has allowed employers to deflect discrimination claims by blaming algorithmic outputs. Under the statute, employers cannot use the fact that an AEDT was used as a defense against a discrimination complaint.

"The law makes clear that employers cannot defend against a discrimination complaint simply because an AEDT was used," legal analysts noted.

This provision mirrors similar protections emerging in Colorado and the European Union, where regulators have moved to mitigate algorithmic bias in high-stakes decisions affecting workers' livelihoods.

Enforcement and Penalties

Unlike many employment statutes, the Connecticut law does not create a private right of action. Individuals cannot sue employers directly for AEDT violations. Instead, enforcement rests exclusively with the state attorney general under the Connecticut Unfair Trade Practices Act (CUTPA).

This structure gives the state sole discretion to pursue violations, which may include failure to provide required notices or using AEDT in ways that produce discriminatory outcomes. The attorney general's office can seek injunctive relief, civil penalties, and other remedies available under CUTPA.

Compliance Timeline

Employers have a phased compliance window. The law becomes effective October 1, 2026, but the written notice requirement does not take effect until October 1, 2027. This gives companies over a year to audit their hiring and HR tech stacks, identify any AEDT in use, and establish disclosure protocols.

Legal observers note that the definition of AEDT is broad enough to cover many common HR tools, including resume screening software, video interview analysis platforms, and performance prediction systems. Companies relying on third-party vendors for these services should verify whether their contracts include indemnification for AEDT-related claims, since the employer — not the vendor — bears statutory compliance responsibility.

Connecticut joins a growing cohort of jurisdictions regulating workplace AI. The law's focus on transparency and accountability, rather than outright bans, reflects a pragmatic approach that acknowledges AI's utility while demanding human oversight of consequential employment decisions.