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Connecticut Enacts AI Responsibility and Transparency Act, Effective October 2026

On 2 June 2026, Connecticut Governor Ned Lamont signed Senate Bill 5 into law as Public Act 26-15, the Connecticut Artificial Intelligence Responsibility and Transparency Act. The law creates disclosure obligations for employers using automated employment decision tools, governance requirements for frontier AI developers, product standards for AI companion systems, and safety obligations for online platforms serving minors. Most provisions take effect 1 October 2026; the Attorney General holds exclusive enforcement authority.

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Governor Ned Lamont signed Senate Bill 5 into law as Public Act 26-15 on 2 June 2026, enacting the Connecticut Artificial Intelligence Responsibility and Transparency Act (CART Act). The law is at the final rule stage. Most provisions enter into force on 1 October 2026, with additional obligations activating on 1 January 2027. Enforcement rests with the Connecticut Attorney General, who must issue a 60-day cure notice before filing suit for violations occurring before 31 December 2027. The Act creates no private right of action.

The Act defines an automated employment decision tool (AEDT) as any technology producing a score, ranking, prediction, or recommendation that constitutes a substantial factor in a hiring, promotion, discipline, discharge, or renewal decision. Frontier developer adopts the compute threshold used in California legislation: an entity training a foundation model using more than 10^26 integer or floating-point operations. Large frontier developers, defined as those with annual gross revenue exceeding USD 500 million, face the most extensive governance obligations. AI companions, defined as systems communicating with individuals in natural language through text, audio, or video to simulate human conversation, face obligations activating on 1 January 2027.

Employers deploying AEDTs in hiring or personnel management must provide disclosure to affected candidates and employees. Employers issuing mass-layoff notices must disclose whether AI informed the reduction-in-force decision. Frontier developers and large frontier developers face safety and governance requirements at the model training and deployment level. Online platform operators serving minors must address AI-related synthetic content and safety obligations under the Act. Content platforms generating or distributing AI-created content must comply with the Act's generative AI provenance provisions.

Healthcare entities receive targeted carveouts within the Act's AI companion provisions. The AEDT obligations interact with existing US Equal Employment Opportunity Commission guidance on AI hiring tools; employers must reconcile Connecticut obligations with applicable federal requirements. The compute-based frontier developer definition aligns Connecticut with California and other US states, but the absence of a federal definition creates compliance asymmetry for operators subject to multiple state regimes.

We advise employers, frontier AI developers, platform operators, and AI system vendors on US state AI law compliance, including Connecticut's CART Act. Work we undertake includes AEDT audit programmes, employment disclosure programme design, frontier developer governance assessments, AI companion regulatory reviews, and multi-state AI regulatory mapping for operators across US jurisdictions.

Source: Connecticut Office of the Governor, Press Release, 2 June 2026

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