Sweeping Workplace Changes Passed by General Assembly - Heads to Governor's Desk

Employment advertising, pay transparency, a new ADA posting, new contractor replacement rules, and additional lactation breaks are all part of a 126-page blockbuster employment law, Public Act 26-12 which was passed and is now headed for the Governor’s signature.

If signed as expected, employers will have multiple compliance deadlines beginning October 1, 2026, with additional provisions taking effect for some employers in 2027.

The regular session of the General Assembly adjourned on May 4, 2026. Below is a breakdown of the key provisions of Public Act 26-15 and what they mean for employers.

Provision: Public Disclosure of Salary Ranges and Benefits for a Position (Effective: October 1, 2026)

This provision requires employers advertising a job opening to include the salary range and a general description of benefits for the position. Significantly, this requirement applies to both public and internal job postings.    

The law defines “benefits” broadly to include health insurance, fringe benefits, paid leave, and any other non-wage compensation. Current law only requires employers to provide the wage range for a position when making an offer of employment to a prospective employee or when an employee requests it.  

Employers should review job posting templates and compensation practices to ensure ranges are accurate, defensible, and consistently applied.

Provision: Employer Guide for Paycheck Codes (Effective Date: October 1, 2026)

Employers with 100 or more employees will be required to create a guide for any pay codes used on paychecks and post them on the internet in English, Spanish, and the other most common languages spoken by their employees. This includes pay codes for on call pay, hazard pay, call-back pay, holiday pay, and pay differentials.

Employers will also need to include the website address for the pay code guide on each pay record issued to the employee.

Provision: Expanded Lactation Break Requirements (Effective Date: October 1, 2026)

This provision requires employers to provide reasonable break time for an employee to express breastmilk, in addition to the employee’s scheduled breaks. Current law allows an employee to express breastmilk or breastfeeding during a meal or break period.

Provision: ADA Posting Requirement (Effective Date: October 1, 2026)

This provision requires employers to give written notice about an employee’s right to reasonable accommodations in the workplace for a disability under the ADA to (1) new employees at the start of their employment; (2) existing employees by January 29, 2027; and (3) any employee who notifies the employer about his or her disability within 10 days after the notification.

Alternatively, an employer can comply with the requirement by displaying the poster created by the DOL commissioner in a conspicuous place, accessible to employees, at the employer’s place of business.

Provision: Expansion of Ban on Employment Repayment Agreements (Effective Date: October 1, 2026)

P.A. 26-12 expands an existing restriction on so-called “claw back,” “training repayment,” or “stay-or-pay” agreements to all employers, regardless of size.

The law prohibits employers from requiring employees or applicants to sign agreements that require repayment if they leave employment within a specified time period, including:

• Training reimbursement agreements; and

• Employment promissory notes tied to tenure.

Limited exceptions remain, such as recovery of money advanced to employees. 

Employers that use training repayment agreements or similar provisions should review and revise those agreements before the provision’s effective date.

Provision: Successor Employer Obligations for Service Contracts (Effective Date: October 1, 2026)

This provision creates significant obligations for businesses who provide or receive service contracting—particularly in industries like janitorial, security, maintenance, and hospitality.

Under this provision, when a business takes over a service contract, outsources services previously performed in-house, or acquires property where covered services were being performed, it must:

• Retain the predecessor’s employees for at least 90 days. During this period employees cannot be terminated without just cause;

 and

• At the end of the 90 days, the employer must conduct performance evaluations and offer continued employment to employees who perform satisfactorily.

The law applies to covered employees who work at least 16 hours per week and have worked at a covered location for at least 60 days. Covered employees are those performing:

• Care or maintenance services, including a security guard, front desk worker, janitor, housekeeper, maintenance employee, concierge, door attendant, building superintendent, grounds maintenance worker, stationary fireman, elevator operator, or window cleaner; and

• Passenger-related security services, cargo and ramp services, in terminal passenger and baggage handling, and cleaning services at an airport.

Covered locations are:

• multi-family residential buildings or complexes with 50 or more units;

• commercial centers or complexes over 75,000 square feet;

• municipal facilities;

• public or nonpublic schools;

• cultural centers or complexes, such as museums, convention centers, arenas, or performance halls;

• shopping malls or bank branches;

• industrial sites;

• pharmaceutical labs;

• airports;

• train stations;

• warehouses, distribution centers, or other facilities that store or distribute general merchandise, refrigerated goods, or other products; and

• private higher education institutions.

The law also imposes notice requirements when a contract ends. Violations of the law’s provisions result in a penalty of between $500 and $1,000 per employee for each day the violation continues.

 Provision: Prevailing Wage for Construction Employers (Effective Date: October 1, 2026)

This provision requires construction employers on public works projects to maintain a daily record of all mechanics, laborers, and workers at the site, including their name, trade license number, and arrival and departure times and submit those records weekly to the contracting agency.

Violations of this requirement result in a class C misdemeanor punishable by a fine of up to $500, imprisonment for up to three months, or both.

Provision: Enhanced Workers’ Compensation Benefits for Teachers and Healthcare Assault Victims (Effective: October 1, 2026)

This provision increases the workers' compensation benefit available to healthcare workers and teachers injured as the result of a workplace assault to 100% of average weekly earnings—uncapped by the usual maximum weekly benefit rate—plus reimbursement for medical expenses and lost wages due to court appearances related to the assault.

In addition, if an teacher or healthcare worker's absence is due to a workplace assault injury or court appearance, the employer must pay the employee 100% of his/her wages and cannot charge the absence to the employee’s sick leave, vacation, or personal leave. 

Provision: Contractor Joint and Several Liability for Wage Theft (Effective: January 1, 2027) 

This provision makes general contractors jointly and severally liable for unpaid wages owed to employees by their subcontractors. It applies to construction contracts entered into on or after January 1, 2027.  

Employees are permitted to bring civil actions against the subcontractor, the contractor, or both, provided they give the contractor at least 30 days’ notice before filing suit.  

Key Takeaways for Employers

P.A. 26-12 represents a significant expansion of employee protections in Connecticut. Employers should:

• Update job posting practices to comply with pay transparency rules;

• Review and revise any repayment or training reimbursement agreements;

• Prepare for successor employer obligations in service contracts;

• Ensure lactation accommodations meet expanded requirements; and

• Evaluate workers’ compensation and leave policies for covered employees.

Editor’s Note: Public Act 26-12 will be explained in detail in the firm’s Annual Employment Law Update (webinar) on September 10, 2026. Those who wish to register early may contact Jessenia Narvaez as jessenianarvaez@robertnoonan.com or call 860-379-7010.