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Connecticut Passes SB 5, the AI Responsibility and Transparency Act, on 11 May 2026

The Connecticut General Assembly passed Senate Bill 5, now branded the Artificial Intelligence Responsibility and Transparency Act, on 11 May 2026. The act binds developers and deployers of automated employment-related decision technology, layers on whistleblower protections for frontier model staff, and adds AI disclosures to WARN notices filed with the Department of Labor. Governor Ned Lamont is expected to sign. Most provisions take effect from 1 October 2026, with interactive disclosure rules following on 1 October 2027.

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The Connecticut General Assembly passed Senate Bill 5 on 11 May 2026. The bill is branded the Artificial Intelligence Responsibility and Transparency Act. Governor Ned Lamont is expected to sign. Effective dates run on a staggered schedule, starting 1 October 2026.

SB 5 sets disclosure and notice duties for employers that deploy automated employment-related decision technology, or AEDT. The act clarifies that the use of AEDT is not a defense to a discrimination claim brought under Connecticut anti-discrimination statutes. SB 5 grants whistleblower-style protections to staff of certain frontier AI developers. It creates internal reporting duties for those developers. SB 5 also adds an AI and technology-change disclosure to WARN Act notices filed with the Connecticut Department of Labor. Plain-language disclosures of AI subscription terms apply to consumer-facing services. Large generative AI providers above one million monthly users must embed provenance data into generated audio, image, or video content.

Employers using AEDT in recruiting, hiring, promotion, demotion, discipline, or termination decisions must update their disclosure and pre-decision notice flows. Hiring platforms, applicant tracking system vendors, and HR analytics vendors selling into Connecticut must give deployer customers the inputs needed to comply. Frontier model developers operating in Connecticut must build internal channels for safety reporting and shield staff who raise concerns. Connecticut employers above the federal WARN threshold must include AI and technology-change content in plant closing or mass layoff notices. Consumer-facing AI providers must add plain language disclosures of subscription terms and provenance marks where applicable.

Most operative provisions begin on 1 October 2026, including the AEDT employer obligations, the anti-discrimination clarifications, the frontier developer whistleblower rules, and the WARN AI disclosure. The interactive disclosure and pre-decision notice obligations for AEDT take effect on 1 October 2027. The Connecticut Attorney General holds exclusive enforcement authority for the AEDT sections under the Connecticut Unfair Trade Practices Act. SB 5 grants an optional 60-day cure period for violations occurring on or before 31 December 2027. SB 5 creates no private right of action for the AEDT sections, but does open a private right of action for violations tied to minors interacting with AI companions.

Licentium advises crypto, AI, and digital asset businesses on US AI legislation, with a partner network for Connecticut local counsel. Work we undertake includes AI hiring tool reviews, AEDT disclosure drafting, frontier developer policy work, WARN notice updates, whistleblower channel design, consumer AI disclosure drafting, and engagement with the Connecticut Attorney General. Contact us for SB 5 readiness work tailored to your Connecticut footprint.

Source: Connecticut General Assembly, Substitute Senate Bill No. 5, Artificial Intelligence Responsibility and Transparency Act, passed 11 May 2026, https://www.cga.ct.gov/asp/cgabillstatus/cgabillstatus.asp?selBillType=Bill&which_year=2026&bill_num=5

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

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