Connecticut Enacts CART Act to Force Transparency in AI Hiring
New law mandates that employers disclose the use of automated decision tools for hiring and promotions.
Governor Ned Lamont signed the Connecticut Artificial Intelligence Responsibility and Transparency Act, known as the CART Act (Public Act 26-15), into law on May 27, 2026. The legislation establishes strict disclosure requirements for companies using automated systems to manage their workforce.
The law targets "automated employment-related decision technology" (AEDT), defined as any technology where the output—such as a score, ranking, prediction, or recommendation—serves as a substantial factor in decisions regarding hiring, promotion, discipline, or termination. Under the new rules, employers must notify candidates and employees whenever they are interacting with AI. Furthermore, companies are required to provide a written pre-decision notice that details the tool's trade name, its specific purpose, the categories of personal data being analyzed, and the sources of that data.
The Push Against 'Black Box' HR
The CART Act arrives as part of a broader national trend toward state-level AI regulation, mirroring similar efforts in California to combat algorithmic bias. The legislation specifically targets the "black box" nature of modern HR software, where decisions are often made by opaque algorithms. By shifting the burden of transparency onto both the software developers, who must provide the necessary data, and the employers, who must disclose it to the worker, Connecticut aims to eliminate the secrecy surrounding automated employment decisions.
Legal Liability and Bias Audits
For the business community, the most significant impact of the CART Act is the removal of the "AI defense" in discrimination cases. The law explicitly states that the use of AEDT does not shield an employer from liability in discrimination claims. However, the legislation does provide a pathway for mitigation; courts and the Commission on Human Rights and Opportunities may consider evidence of rigorous anti-bias testing as a mitigating factor. This creates a direct financial and legal incentive for companies to conduct and document comprehensive bias audits of their HR technology stacks.
Implementation Timeline
Compliance with the CART Act will be phased in over the next year. Obligations for developers to share information begin on October 1, 2026. Employer notice requirements for newly deployed AEDTs will take effect on October 1, 2027.
Regarding enforcement, the law grants no private right of action, meaning employees cannot sue individually under this specific act. Only the Attorney General may bring suit. A mandatory cure period for violations will run from October 1, 2026, through September 30, 2027, after which any opportunities to cure violations will be discretionary.