Connecticut employers must prepare for significant new employment requirements that became effective on October 1, 2026. Public Act 26-12 expands pay-transparency requirements and adds new pay-code, workplace-notice, and lactation obligations while broadening restrictions on employment promissory notes. Public Act 26-15 separately regulates employers’ use of artificial intelligence and automated employment-related decision-making technology. Employers with Connecticut operations should act now—our Labor & Employment Practice Area attorneys can help you assess these obligations and update your policies to ensure your business is compliant.
Updates to Pay Transparency and Pay Codes
Employers must include a position’s wage or wage range—set in good faith—and a general description of benefits in all public and internal job advertisements. This applies to positions with duties performed in Connecticut and to out-of-state positions reporting to a Connecticut supervisor, office, or work site.
Employers with 100 or more employees must also create a guide explaining their overtime pay codes and most commonly used pay differentials—such as shift, on-call, hazard, holiday, or weekend pay—and make it available to employees as the statute requires.
Expansion of Disability Accommodation and Lactation Requirements
Employers must provide written notice of employees’ rights to reasonable workplace accommodations for a disability under the Americans With Disabilities Act. Notice must be provided to new employees at the start of employment; to existing employees within 120 days after October 1, 2026; and within 10 days after an employee informs the employer of a disability. Employers may satisfy the requirement by conspicuously displaying the notice prepared by the Connecticut Labor Commissioner in an area accessible to employees.
Employers must also provide reasonable break time, in addition to regularly scheduled breaks, for employees to express breast milk or breastfeed at work.
Revised Restriction on Employment Promissory Notes
Public Act 26-12 eliminates the prior 26-employee threshold, so the restriction on employment promissory notes now applies to employers of all sizes. It prohibits agreements required as a condition of employment that obligate an employee to pay the employer—including reimbursing the cost of previously provided training—if the employee leaves before a specified period.
Noncompliant promissory notes executed on or after October 1, 2026, are void as against public policy, though certain statutory exceptions remain. Employers should have legal counsel review training repayment and similar agreements before entering into any new agreement on or after the effective date. Our Labor & Employment Practica Area attorneys can help you assess and update these arrangements.
Provision Regarding the Use of Artificial Intelligence in Employment Decisions
Public Act 26-15 addresses automated employment decision-making technology. Use of this technology is not a defense to an unlawful employment discrimination claim, and the Commission on Human Rights and Opportunities (CHRO) or a court may consider evidence of anti-bias testing or similar efforts in evaluating these claims.
The Worker Adjustment and Retraining Notification (WARN) Act’s principal disclosure and advance-notice requirements apply to covered technology deployed on or after October 1, 2027. Beginning October 1, 2026, employers filing federal WARN Act notices with the Connecticut Department of Labor must also disclose whether layoffs relate to artificial intelligence or another technological change.
Employer Takeaways
Connecticut employers should promptly review their job postings, pay-code practices, accommodation and lactation policies, training-repayment agreements, and use of AI and automated employment tools. Our Labor & Employment Practice Area attorneys regularly help employers close compliance gaps and update policies—contact us to ensure your organization is adhering to these new requirements.
If you have any questions regarding the content of this alert, please contact Lizz Acee, partner, at eacee@barclaydamon.com; Dan Elliott, partner, at delliott@barclaydamon.com; Jenna Cutler, associate, at jcutler@barclaydamon.com; or another member of Barclay Damon’s Labor & Employment Practice Area.
Patrick Crowley, law clerk (not admitted to the practice of law), contributed to the preparation of this alert.