New Connecticut Laws Taking Effect October 1, 2026: What Employers Need to Know
In a highly controversial action in this term of the Connecticut General Assembly, the legislature passed a 124 page bill, Public Act 26-12 (P.A. 26-12), which contained what would otherwise have been several independent bills pertaining to the workplace.
This Thursday, October 1st, P.A. 26-12 will bring a significant number of new employment-law requirements for Connecticut employers, covering everything from new posting requirements for pay transparency and employee accommodations to workplace surveillance and artificial intelligence.
While some of the new laws impose entirely new obligations, others expand requirements that employers may already be familiar with. Employers should review their hiring practices, workplace notices, employee policies, payroll and recordkeeping procedures, and use of technology to ensure compliance with the changes taking effect this fall.
We outline the new laws taking effect October 1 below:
Omnibus Bill: P.A. 26-12
Provision: Posting Wage Ranges and Benefit Descriptions on Job Advertisements
Beginning October 1st, employers advertising job openings will be required to include both the wage range for the position and a general description of the benefits available for the position in public and internal job postings. Employers also must provide this information to applicants when requested or before discussing compensation, whichever occurs first, and to employees who request the information or who change positions.
The required benefits disclosure is similarly broad. A general description may include health insurance, retirement benefits, fringe benefits, paid leave, and other forms of compensation other than wages. The disclosure does not have to provide extensive detail. For example, an employer could generally describe its benefits as including medical, dental and vision insurance, a 401(k) with an employer match, paid time off, paid holidays, and other fringe benefits.
For employers, the practical takeaway is that job-posting practices will need to be reviewed. Employers should make sure that both external and internal postings contain the required wage and benefits information and that their compensation practices are sufficiently documented to support the wage ranges being provided.
Note however, that it would be prudent to include in the benefits statement that the plan documents are controlling and that benefits are subject to change at the sole discretion of the organization.
Provision: Additional Lactation Break Requirements
Employers will face expanded obligations concerning lactation breaks. Under current law, employers generally must allow employees to use existing meal and break periods to express breast milk. Beginning October 1st, employers will be required to provide additional reasonable break time for this purpose. The expanded requirement brings Connecticut law more closely in line with the federal Pregnant Workers Fairness Act.
The existing requirements concerning the location where an employee may express breast milk remain. Employers must make reasonable efforts to provide a room or other location that is near the employee's work area, is private, is near a refrigerator or other cold-storage device, and has access to an electrical outlet. The location cannot be a toilet stall.
Employers should therefore make sure that managers understand that employees may be entitled to additional break time beyond regularly scheduled meal or rest periods and that an appropriate private location is available.
Provision: New Notice Requirement to Employees on ADA Accommodations
Employers also will have a new notice obligation concerning employees' rights to reasonable accommodation under the Americans with Disabilities Act. Beginning October 1st, employers must provide written notice to new employees at the start of employment explaining their right to reasonable accommodation. Existing employees must receive the notice by January 29, 2027. In addition, an employee who notifies the employer of a disability must receive the notice within 10 days of that notification.
Employers have an alternative means of satisfying the requirement. Rather than providing the notice individually, an employer may post a notice created by the Connecticut Department of Labor in a conspicuous location accessible to employees at the employer's place of business. The CT DOL notice is available on our website under forms here.
Employers should consider how the individual notice requirement will be handled when an existing employee raises a disability-related issue during employment.
Provision: Paycheck Pay Code Guides (For Employers with 100 or More Employees)
Beginning October 1st, employers with 100 or more employees will be required to create and provide to employees a guide explaining the pay codes used for overtime and the most commonly used pay differentials, including such items as shift differentials, on-call pay, and holiday or weekend pay.
The guide must contain at least 10 pay codes and must be made available in English, Spanish, and the other languages most commonly spoken by the employer's employees. It also must identify the office or person responsible for handling employee disputes concerning calculations of hours and pay differentials.
Employers may satisfy the requirement by posting the guide on their website or by providing employees with a written copy. An employer is also treated as compliant if they use a third-party payroll service that supplies a pay-code guide meeting all of the statute's standards. Employers subject to this provision should therefore begin identifying their most commonly used pay codes and differentials and determine how the required information will be communicated to employees.
Provision: Broader Prohibition on Employment Promissory Notes
Connecticut's prohibition on requiring employees to sign certain employment-related promissory notes as a condition of their employment will expand to cover all employers. Currently, the prohibition applies to employers with 26 or more employees.
An employment promissory note generally involves an agreement requiring an employee to pay money to the employer if the employee leaves employment before a specified period. One common example is an agreement requiring an employee to repay training costs if the employee leaves shortly after completing the training. These agreements will generally be prohibited beginning October 1st.
The law does contain exceptions. Among other things, the definition of a prohibited promissory note does not include agreements requiring repayment of advances, payment for property sold or leased to an employee, certain educational personnel sabbatical arrangements, or collectively bargained programs.
Employers of all sizes should therefore review agreements that require employees to repay money upon separation and determine whether any such arrangements fall within the expanded prohibition.
Provision: Enhanced Workers' Compensation Benefits for Certain Assaulted Workers
The law also changes workers' compensation benefits available to certain employees who are unable to work because of an on-the-job assault. The affected employees include teachers, healthcare providers, board of education members, and their employees.
For qualifying injuries, these employees will receive 100% of their average weekly earnings rather than the standard 75% after-tax cap. The law also provides for medical expenses and lost wages associated with court appearances.
Importantly for employers, time away from work resulting from an assault-related injury or court appearance cannot be charged against the employee's sick leave, vacation, or personal leave.
Employers with employees covered by this provision should make sure that HR and payroll personnel understand that qualifying absences must be treated differently from ordinary leave.
Provision: New Recordkeeping Requirements for Prevailing Wage Projects
Contractors and subcontractors working on projects subject to Connecticut's prevailing wage requirements will face new daily attendance recordkeeping requirements. The law will require such employers to maintain attendance records for mechanics, laborers, and other workers at covered job sites.
The records must identify the project and its location, the date, each worker's name and applicable trade license number, and each worker's arrival and departure times. The records must be submitted weekly to the agency that issued the contract.
Employers should be aware that these records are treated as public records and therefore are subject to the Freedom of Information Act. Contractors working on covered projects should ensure that their timekeeping and job-site attendance systems are capable of capturing the required information.
Provision: Direct Care Employee Access to Virtual Monitoring Evidence
P.A. 26-12 will give certain direct-care employees greater access to evidence obtained through virtual monitoring. Employees of nonprofits and contractors providing direct-care services to individuals enrolled in programs administered by DSS will have the right to review virtual monitoring data when that information is being relied upon as evidence in proposed disciplinary proceedings. Unions representing those employees may also obtain the evidence.
The law defines virtual monitoring as remote monitoring of an individual receiving direct-care services through technology owned and operated by that individual in the individual's home.
Access to the evidence is subject to confidentiality protections. Employees and union representatives requesting the information must agree to an approved confidentiality agreement, treat the recordings or images as confidential, and refrain from copying, reproducing, or further disseminating the evidence.
For covered employers, this provision may affect the disciplinary process when allegations concerning an employee's conduct are based on virtual monitoring technology.
Other Laws Taking Effect October 1st
P.A. 26-73: Expanded Requirements for Electronic Employee Monitoring
Connecticut is also expanding employer notice requirements to employees concerning electronic surveillance. Existing law generally requires employers to provide written notice concerning electronic monitoring that may affect employees and to post the notice in a conspicuous location accessible to employees.
Beginning October 1st, employers will have additional obligations. The required notice must identify the specific workplace locations where employees may be subject to electronic monitoring, and the notice must be posted in the locations where monitoring may occur. Employers also must provide prospective employees hired on or after October 1st with a written, plain-language statement identifying activities that may be monitored without prior written notice.
There is an important exception for security and employee safety. An employer does not have to disclose specific monitoring locations when it has reasonable grounds to conduct monitoring for security or employee-safety purposes.
Employers using cameras, electronic tracking, computer monitoring, or other forms of electronic surveillance should review their existing notices and monitoring practices before the new requirements take effect.
P.A. 26-15: New Rules Addressing Workplace Use of Artificial Intelligence
Several provisions taking effect October 1st address the use of artificial intelligence in the workplace.
First, Connecticut's Fair Employment Practices Act will expressly provide that an employer's use of AI employment-related decision technology is not a defense to a discrimination claim. In other words, an employer cannot avoid responsibility for a discriminatory employment decision simply by pointing to the fact that the decision was made or assisted by an AI-based system.
This provision is particularly significant as employers increasingly use technology in recruiting, hiring, promotion, performance management, and other employment decisions. Employers should understand how AI tools are being used and should not assume that relying on a third-party technology vendor eliminates potential discrimination liability.
The new law also adds an AI-related disclosure requirement under Connecticut's WARN Act. Employers required to submit WARN Act notices to the Connecticut Department of Labor will need to disclose whether a plant closing or mass layoff is the result of the employer's use of AI or another technological change.
Finally, during the term of a covered collective bargaining agreement, AI technology may not be used in a manner that modifies or impairs the terms of the agreement, the designated employee organization's role as the exclusive representative of the bargaining unit, or the relationship between the employer and the employee organization concerning the bargaining unit.
Employers using AI in the workplace should therefore consider not only discrimination implications, but also whether the technology affects existing collective bargaining obligations.
P.A. 26-89: Self-Checkout Surveillance in Employee Lounges
One of the more narrowly focused changes addresses electronic surveillance associated with self-checkout kiosks in employee lounges and similar areas.
Connecticut law generally prohibits employers from using electronic surveillance to monitor employees in areas designed for employee health or personal comfort or to safeguard employees' possessions. The new law creates a limited exception for vendors operating self-checkout kiosks in these areas.
Under the new law, a vendor may use electronic surveillance in connection with a self-checkout kiosk, provided that the surveillance does not record sound and is limited to the checkout area. For example, a hospital may operate a snack area in an employee lounge where employees purchase food through a self-checkout kiosk. The vendor operating the kiosk may use video surveillance of the checkout area even though the kiosk is located in an employee area otherwise protected by Connecticut's surveillance restrictions.
The law also limits the employer's access to the surveillance footage. An employer may not request to view the vendor's surveillance video unless the vendor reports an alleged theft by an employee. The employer therefore cannot use the vendor's surveillance system for general monitoring of employees or request footage simply to observe activity in the lounge.
For employers, the practical effect is a narrowly defined exception that allows vendors to protect self-checkout operations without opening the door to broader employer surveillance of employee lounge areas. Employers using these systems should confirm that surveillance is limited to the checkout area, does not capture audio, and is not accessed except in connection with a vendor-reported allegation of employee theft.
Takeaways for Connecticut Employers
The October 1st changes cover a wide range of employer obligations, and there is no single compliance step that will address all of them. Employers should consider conducting a compliance review that includes:
Recruiting: Review job postings and internal postings to ensure they contain the required wage-range and benefits information.
Accommodation practices: Update onboarding and workplace notices concerning employees' rights to reasonable accommodation under the ADA.
Lactation accommodations: Review break-time and private-space practices to account for the new requirement to provide additional reasonable break time.
Payroll: Determine whether the new paycheck transparency requirements apply and, if so, prepare the required pay-code guide.
Employment agreements: Review training-repayment and other agreements that could constitute prohibited employment promissory notes.
Electronic monitoring: Update electronic-monitoring notices and identify the workplace locations where monitoring occurs.
AI: Review the use of AI in hiring and other employment decisions and consider its potential implications under Connecticut's discrimination and collective bargaining laws.
Recordkeeping: Ensure that covered prevailing-wage projects have systems in place to capture the required daily attendance information.
Industry-specific requirements: Employers in health care, education, direct care, and other covered industries should identify the provisions specifically applicable to their workforces.
Holiday Survey
Because the Christmas and New Year’s holidays fall on Fridays (thus, the Eves are on Thursdays), holiday scheduling for the holiday weeks will be a consideration. Our Annual Holiday Survey will be going out on October 14, 2026. Participants will receive the advance copies of the results.
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