Carmody Labor & Employment partner Nick Zaino shares what employers need to know about from the 2026 legislative session:

  • Disclosure of Wage Ranges in Job Advertisements
  • Notice of ADA Rights
  • Paycheck Transparency
  • Artificial Intelligence Responsibility and Transparency
  • Electronic Monitoring of Employees

The Connecticut legislative session ended on May 6, 2026, and many new employment laws are expected to take effect. Most are included in Public Act 26-12, “An Act Concerning Workforce Development and Working Conditions in the State,” which was signed into law by Governor Lamont yesterday. Below are summaries of several key provisions impacting employers.

Disclosure of Wage Ranges in Job Advertisements (Effective October 1, 2026)

Employers will be required to include a position’s wage or wage range, and a general description of the position’s “benefits” in public and internal job advertisements. “Benefits” includes health insurance, retirement, fringe benefits, paid leave and any other compensation, other than wages, offered with the position.

If a position has not been made available to an applicant pursuant to a job advertisement, the employer must provide the wage range and benefit information upon the earlier of: (a) the applicant’s request; or (b) prior to any discussion of compensation with, or offer of compensation to, the applicant.

The new law sets a stricter standard for establishing wage ranges by requiring employers to set wage ranges “in good faith” as opposed to setting ranges that the employer “anticipates relying on when setting wages.”  The new law expands anti-retaliation protections for employees but removes a court’s ability to award punitive damages.

Lastly, the new law applies to any position in which the job duties will be performed in Connecticut or where the duties are performed outside Connecticut, but the employee reports directly to a supervisor, office or worksite located in Connecticut. 

Breastfeeding and Lactation in the Workplace (Effective October 1, 2026)

Employers will be required to provide “reasonable break times” for an employee to express breast milk for the employee’s nursing child or breastfeed on site at the employee’s workplace, in addition to the employee’s scheduled breaks. The current law limits the employee’s right to express breast milk or breastfeed during meal or break period.  The new law does not define what constitutes “reasonable break times.”

Enhanced Workers Compensation Benefits for Certain Employees Assaulted at Work (Effective October 1, 2026)

Certain healthcare workers, teachers and other related employees will be entitled to enhanced workers’ compensation benefits if they become totally or partially unable to work due to any physical or negligent assault upon them while performing their job duties. These workers also will be entitled to reimbursement for expenses incurred for medical and other services needed and any lost wages incurred to attend any court appearances in connection with the assault. Further, any such absence from work could not be charged against the employee’s sick leave, vacation time, or personal leave.  

Prohibition of Employment Promissory Notes (Effective October 1, 2026)

Connecticut law currently prohibits employers with 26 or more employees from requiring, as a condition of employment, any employee or prospective employee to execute an “employment promissory note.”  Under the new law, this prohibition extends to all employers.

An employment promissory note is any instrument or agreement that requires an employee to pay the employer a sum of money if the employee leaves employment before the passage of a stated period of time. For example, employers are prohibited from requiring an employee to repay training costs that the employer incurred if the employee leaves employment before a certain period of time. The law does not prohibit or render void any agreement: (a) requiring employees to repay sums advanced to the employee; (b) requiring an employee to pay the employer for any property it has sold or leased to the employee; (c) requiring educational personnel to comply with agreed-upon terms and conditions of a sabbatical leave; or (d) entered into with a labor union.

Protections for Warehouse Workers (Effective July 1, 2026)

This new law applies to employers with 250 or more employees at a single warehouse distribution center in Connecticut or with 1,000 or more employees across multiple such centers in Connecticut. It includes numerous provisions such as: (1) a requirement to give employes a written description of quotas they must meet and consequences for failing to do so; (2) restrictions on the implementation of quotas that prevent compliance with Connecticut law on meal periods, interfere with employee use of bathroom facilities, or set certain types of performance standards; (3) a requirement that employers adhere to certain recordkeeping and notice requirements; and (4) protections for employees from discharge and retaliation for exercising their rights under the law.   

Notice of ADA Rights (Effective October 1, 2026)

Employers must provide employees written notice of their right to reasonable accommodations for a disability pursuant to the Americans with Disabilities Act (ADA) to: (a) new employees at the commencement of employment; (b) existing employees within 120 days of October 1, 2026; and (c) any employee who notifies the employer of their disability within 10 days. An employer may comply with these notice obligations by conspicuously displaying a poster created by the Connecticut DOL.

New Prevailing Wage Requirements and Contractor Liability for Unpaid Wages (Effective October 1, 2026)

Employers covered by prevailing wage laws will be subject to various new recordkeeping requirements including daily attendance records. Effective January 1, 2027, construction contractors would be jointly and severely liable for any unpaid wages owed to a subcontractor’s employees.

Paycheck Transparency (Effective October 1, 2026)

Employers with 100 or more employees will be required to create a guide for their employees on the pay codes used for overtime and commonly used pay differentials such as on-call pay, hazard pay, call-back pay, holiday and weekend pay, or geographic pay differentials. The guide must, if applicable, include at least 10 pay codes, be posted on the employer’s website in English, Spanish and other common languages spoken by employees, and include the contact information for the office or person who handles pay disputes. Employers must update the guide each time a new pay code is added, include a link to the guide on each record of hours given to the employee, and give new employees a link to the guide upon hire or provide a written copy of the guide.

Artificial Intelligence Responsibility and Transparency (Effective October 1, 2026)

The Connecticut Artificial Intelligence Responsibility and Transparency Act is a comprehensive law regulating the use of artificial intelligence, including in the workplace.  Effective October 1, 2026, employers who are required to file WARN notices with the state labor department before plant closings and mass layoffs must disclose to the department whether the layoffs are related to the employer’s use of AI or another technological change.

Effective October 1, 2027, employers who use an “automated employment-related decision technology”, which is broadly defined, to interact with employees or job applicants must inform them, in plain English, that they are interacting with the automated technology unless it would be obvious to a reasonable person that they are doing so. In addition, employers that use automated decision technology to make an employment-related decision must provide advance written notice to employees or job applicants informing them of the use such technology, the technology’s purpose and the nature of the employment related decision, the technology’s trade name, the category or sources of personal data that the technology will analyze or process and how it will be assessed, and the employer’s contact information.

The law states that the use of automated employment-related decision technology is not a defense against a complaint alleging a discriminatory employment practice. A court or the Commission on Human Rights & Opportunities may, however, consider any evidence of anti-bias testing or other proactive efforts to avoid discriminatory practices when determining whether unlawful discrimination has occurred, including the quality, efficacy, recency and scope of the testing or other proactive efforts, their results and any response to them.

Violations of the Act’s provisions related to the use of automated employment-related decision technology is deemed an unfair or deceptive trade practice enforceable by the Attorney General (not by a private cause of action or class action). 

Electronic Monitoring of Employees (Effective October 1, 2026)

A bill passed by the legislature, but not yet signed by the Governor, would amend Connecticut’s current law that requires employers to provide employees with notice of the type of electronic monitoring that may occur. The new law would also require employers who electronically monitor their employees to: (1) include the specific workplace locations that may be monitored in the notice they currently are required to post about the types of monitoring that may occur; (2) post the notice in the locations where monitoring may occur; and (3) give prospective employees hired on or after October 1, 2026, a written statement in plain language advising which activities are prohibited and may be monitored without prior written notice.

Retention of Service Contract Workers (Effective July 1, 2027)

The law provides enhanced job protection for some employees (e.g., janitors, security guards, front-desk workers, maintenance employees, building superintendents) who provides certain services at one of the following covered locations: large multifamily residential buildings; commercial centers or office complexes; municipal office buildings or facilities; public or non-public schools; cultural centers or complexes; shopping malls or bank branches; industrial sites; pharmaceutical labs; airports; train stations; warehouses, distribution centers, or other facilities in which the primary purpose is the storage or distribution of products; and independent institutions of higher education.

The law requires covered entities that: (a) take over certain service contracts at covered locations, (b) contract out services, or (c) receive property in a sale or transfer, to retain covered employees from a prior contractor for 90 days if the employees worked during the previous 90 days. The successor employer must provide the covered employees with a performance evaluation after 90 days and continue their employment if their performance is satisfactory during such period.

The law contains numerous other requirements including: advance notice to a terminated contractor, the employees of a terminated contractor, and to any bargaining representative of the terminated contractor’s employees; and required language for a written offer letter that a successor employer must hand-deliver to an employee in their native language or any other language in which such employee is fluent. The new law states that a successor employer is not required to “retain any employee whose attendance and performance records, while working under the terminated service contract, would lead a reasonably prudent employer to terminate the employee.”

The law permits employees who are displaced or terminated in violation of the law to file a complaint with the labor commissioner or the Superior Court, which may award the employee back pay, benefits, reinstatement, compensatory damages, attorney’s fees and costs.

Minimum Wage at Cannabis Establishments (Effective October 1, 2026)

This law prohibits the labor commissioner from counting tips that employees may receive for their work at a cannabis establishment, dispensary facility or producer toward meeting Connecticut’s minimum wage requirement.

If you have questions about Connecticut’s new employment laws, please contact our Labor & Employment team:

Nick Zaino
Partner
[email protected]
203.578.4270

Carmody’s Labor & Employment lawyers are dedicated to delivering practical counsel on the full range of employment issues to public and private employers and nonprofit entities of all sizes.

This information is for educational purposes only to provide general information and a general understanding of the law. It does not constitute legal advice and does not establish any attorney-client relationship.