The Connecticut General Assembly passed Substitute Senate Bill 5 on 11 May 2026. Governor Ned Lamont signed the bill as Public Act 26-15. The Act is final, signed legislation. Developer duties take effect 1 October 2026. Deployer obligations take effect 1 October 2027. The Act covers automated employment decision tools, AI companion chatbots, frontier model whistleblowing, and synthetic content provenance.
Public Act 26-15 amends Connecticut General Statutes Title 31 (Labor) and Title 46a (Human Rights and Opportunities). The Act applies to any AI tool used as a substantial factor in hiring, promotion, discipline, pay, or discharge decisions. Developers must disclose to deployers the tool's intended uses, training data categories, known limitations, and bias testing results. Deployers must notify affected applicants and employees of the use of the tool, its purpose, the data categories used, and the data sources. The Act also amends Sections 46a-58 and 46a-60 to clarify that automated decision-making is not a defense to a discrimination claim. New Section 31-51n requires employers serving layoff notices to disclose whether the layoffs relate to AI use or other technological change. Pre-deployment impact assessments and post-deployment monitoring are required for substantial-factor employment tools.
Employers using AI in hiring, performance, or workforce planning face new disclosure, testing, and recordkeeping duties. AI vendors selling automated employment decision tools must produce compliance documentation for Connecticut deployer customers. Plaintiff-side employment counsel gain new statutory hooks for discrimination and notice claims. Workforce reduction announcements involving algorithmic management or AI-led restructuring now trigger Labor Department disclosure. Companion-chatbot and frontier model rules apply to a separate set of developers and operators, with the Connecticut Attorney General as the civil enforcement authority.
The Act provides a limited mitigation defense where employers run proactive anti-bias testing. There is no private right of action for the employment provisions. The Connecticut Attorney General holds sole civil enforcement authority. Public Act 26-15 does not preempt local Connecticut ordinances or sector-specific federal rules. Federal contractors continue to follow OFCCP and EEOC obligations on top of the state regime.
Licentium advises AI vendors, employers, and HR platforms on US state AI employment laws, and coordinates with a partner network of US labor and employment counsel. Work we undertake includes automated employment decision tool reviews, bias testing protocols, Connecticut PA 26-15 deployer documentation, applicant notice templates, labor-side disclosure scripting, and contract uplift between AI vendors and employer deployers. Contact us to scope a Connecticut compliance review.
Source: Connecticut General Assembly, Substitute Senate Bill No. 5, Public Act No. 26-15, signed May 2026, https://www.cga.ct.gov/2026/act/pa/pdf/2026PA-00015-R00SB-00005-PA.pdf
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