Important Employment Legislative Changes – 2026
HRLA of Eastern Connecticut — Legislative Liaison Update
May 5, 2026
I’m pleased to serve as HRLA of Eastern Connecticut’s new Legislative Liaison. In this role, I will provide updates on new and pending Connecticut legislation relevant to HR professionals. This first update covers two major bills passed by the General Assembly in the final days of the 2026 session, both of which carry near-term compliance deadlines for Connecticut employers.
Connecticut’s Omnibus Workforce Bill (House Bill 5003): “An Act Concerning Workforce Development and Working Conditions in Connecticut”
HB 5003 is one of the most ambitious workforce packages Connecticut has enacted in recent years. The provisions most likely to land on your desk are summarized below.
Wage Transparency Expansion (Effective October 1, 2026):
Connecticut’s wage transparency law is being significantly expanded. Previously, employers had to provide a wage range only on an applicant’s request or when making an offer. Under the new law, all employers must include in both internal and public job postings the position’s wage range and a general description of benefits — including health insurance, retirement, fringe benefits, paid leave, and other non-wage compensation. The bill also strengthens anti-retaliation protections and extends the statute of limitations from one year to two.
Action items: Update job posting templates, train recruiters on the new disclosure requirements, and review internal processes for position changes to ensure timely communication.
Employment Promissory Notes Effectively Banned (Effective October 1, 2026):
The bill substantially expands the prohibition on employment promissory notes, i.e., agreements requiring employees to repay an employer if they leave before a stated period. Any such note executed on or after October 1, 2026 will be void as against public policy. Narrow exceptions remain for repayment of advances, payment for property sold or leased to the employee, educational sabbatical leave terms, and collectively bargained programs.
Action items: Audit onboarding documents, training agreements, and retention bonus structures. If your organization uses repayment obligations tied to early departure, consult counsel before October 1 to confirm whether the agreements fall within a narrow exception.
Mandatory Lactation Accommodations (Effective October 1, 2026):
The existing lactation accommodation law is being upgraded from largely permissive language to affirmative employer mandates. Employers must provide reasonable break time (in addition to regularly scheduled breaks) for employees to express breast milk or breastfeed on site. Employers must also make reasonable efforts to provide a private space—not a toilet stall—that is free from intrusion, shielded from public view, located near a refrigerator or portable cold storage device, and equipped with access to an electrical outlet. The law applies to any employer with one or more employees.
Action items: Evaluate current lactation spaces against each requirement and update the employee handbook to reflect the mandatory nature of these breaks.
New ADA Accommodation Notice Requirement (Effective October 1, 2026):
Employers must provide written notice of an employee’s right to reasonable accommodations under the ADA: (i) to new employees at the start of employment; (ii) to existing employees within 120 days of October 1, 2026 (i.e., by January 29, 2027); and (iii) to any employee who notifies the employer of a disability, within 10 days of that notification. Employers may comply by displaying a poster issued by the Labor Commissioner in a conspicuous, accessible location.
Action items: Watch for the Labor Commissioner’s poster, incorporate the notice into onboarding, and calendar the January 29, 2027 deadline for notifying existing employees.
Pay Stub Transparency for Large Employers (Effective October 1, 2026):
Employers with 100 or more employees must publish a guide to their pay codes for overtime and commonly used pay differentials, including shift differentials, on-call pay, hazard pay, call-back pay, holiday or weekend pay, and geographic differentials. The guide must include at least 10 pay codes (where applicable); be posted on the employer’s website in English, Spanish, and the other languages most commonly spoken by employees; and identify a designated contact for disputes. Employers using third-party payroll services that provide an adequate guide are deemed in compliance.
Successor Employer Obligations (Effective July 1, 2027):
The bill creates a new framework requiring successor employers on service contracts (and in certain property sales or transfers) to retain the predecessor’s workforce for at least 90 days. During the transition period, successor employers may not discharge retained employees except for “just cause” based solely on individual performance or conduct. Penalties range from $500 to $1,000 per employee per day for failure to retain, and $50 to $200 per employee per day for notice violations.
Other Notable Provisions:
The bill also imposes joint and several liability on contractors for unpaid wages (effective January 1, 2027), enhances workers’ compensation benefits for healthcare and education employees assaulted on the job, adds prevailing wage record-keeping requirements for public works projects, and updates labor peace agreement requirements in the cannabis industry.
Connecticut’s AI Responsibility and Transparency Act (Senate Bill 5)
The General Assembly has also given final approval to SB 5, the Connecticut Artificial Intelligence Responsibility and Transparency Act, which Governor Lamont has indicated he will sign. SB 5 is a broad AI and online safety bill with several provisions that directly affect hiring and HR operations, with staggered effective dates beginning October 1, 2026.
New Disclosure Requirements for Automated Tools in Hiring and HR:
SB 5 regulates “automated employment-related decision technology,” defined broadly to include any technology that processes personal data and produces an output (e.g., a score, rank, recommendation, or classification) that is a substantial factor in, or materially influences, an employment-related decision. The definition can reach resume-screening software, assessment tools, scheduling algorithms, performance analytics, and third-party hiring platforms.
Beginning October 1, 2027, an employer using such a tool to interact with applicants or employees must disclose, in plain language, that the individual is interacting with the technology, unless a reasonable person would find that fact obvious. When the tool will be a substantial factor in a decision, the employer must also provide a written pre-decision notice identifying the tool’s trade name, purpose, the categories and sources of personal data analyzed, how the data is assessed, and employer contact information.
For employers using third-party systems, the statute imposes duties on tool “developers” to provide the information employers (as “deployers”) need to satisfy their obligations. Developers and deployers may contractually allocate notice duties, but any allocation must be explicit. The developer-deployer allocation provisions take effect October 1, 2026.
Action items: Inventory where automated decision tools touch the employee lifecycle, from sourcing through performance management; standardize pre-decision notices that accurately describe purpose, trade name, and the categories and sources of data; and review vendor agreements to secure the information needed to meet deployer duties and to allocate responsibility appropriately.
“AI Is Not a Defense” in Discrimination Cases:
Beginning October 1, 2026, SB 5 amends the Connecticut Fair Employment Practices Act to state expressly that the use of automated employment-related decision technology is not a defense to a discrimination claim. The Commission on Human Rights and Opportunities (CHRO) or a court may, however, consider evidence of anti-bias testing or similar proactive measures, including the quality, recency, scope, and results of such testing. While this is not a safe harbor, it creates a clear incentive for pre-deployment and ongoing validation of automated tools.
Action items: Work with vendors to operationalize anti-bias testing of automated tools, and document the testing methodology, results, and any corrective action.
WARN Act Disclosure for AI-Related Layoffs:
Beginning October 1, 2026, any employer filing a WARN Act notice with the Connecticut Department of Labor must also disclose whether the layoffs are related to the employer’s use of artificial intelligence or other technological change. This will require coordination among HR, legal, operations, and communications teams whenever a reduction in force implicates automation or AI-enabled systems.
Action items: Build a cross-functional protocol for HR, legal, operations, and communications to evaluate and document AI or technological causation before any WARN Act notice is filed.
If you have questions about how these new laws may affect your organization, please reach out to me or to your employment counsel.
One final note: the Connecticut legislative session closes May 6, 2026, so additional bills or amendments may pass in these final hours. Further updates may follow.
— Emily McDonough Souza
The information in this update is provided in my capacity as a board member and legislative liaison and does not constitute legal advice. Members are encouraged to consult with legal counsel regarding specific compliance questions.
