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Get Ready Connecticut Employers: New Laws Take Effect October 1, 2026

Date   Sep 23, 2026

The Connecticut Legislature took an active look at its employment laws in 2026 and made changes to several. With the deadline looming, employers should ensure they are prepared. The following discussion highlights some of the most significant generally applicable changes to Connecticut’s employment laws.

Pay Transparency

Since 2021, Connecticut has required employers to disclose pay ranges to applicants either upon request or when making an employment offer, whichever occurs first. Effective October 1, 2026, the law is amended to require disclosures earlier in the hiring process. Employers will be required to provide the “wage range” and a description of benefits in job postings or, where there is no job posting, before any conversation about wages or an employment offer is made. “Wage range” was redefined to mean any range of wages an employer “sets in good faith for a position,” while “benefits” include “health insurance benefits, retirement benefits, fringe benefits, paid leave and any other compensation other than wages to be offered with a position.”

The new requirements apply to all employees in Connecticut or employees located outside of Connecticut who report to a supervisor, office, or worksite within Connecticut.

Pay Codes

Employers with 100 or more employees will now be required to provide employees with a written guide describing pay codes governing overtime and the most common pay differentials. Employers must include a minimum of 10 pay codes and provide information about who an employee should contact to dispute their hours and pay differential calculations. The guide must be in English, Spanish, and the language most commonly spoken by employees in the workforce, posted on the employer’s website (if the employer has one), and the URL circulated to employees.

Like the pay transparency law, this applies to employees working in Connecticut or employees working outside of Connecticut who report to a supervisor, office, or worksite within the state.

Electronic Monitoring

Effective October 1, 2026, employers will be required to post notices specifically identifying the location in which electronic monitoring is being conducted. The notice must be posted at the specific location where the monitoring is taking place. Employers will also be required to provide new employees with a written statement that they may be subject to electronic monitoring. The key change in this law is the location-specific notification requirement and the explicit notification required at the time of hire.

"Electronic monitoring" is any collection of information through electronic means, other than direct observation, on an employer’s premises about an employee’s activities or communications. Electronic means can include the use of computers, telephones, cameras, or electromagnetic systems.

Among the exceptions are that notice is not required for monitoring being conducted in common areas held out for public use (such as lobbies). Notice also is not required where an employer has reasonable grounds to conduct monitoring for security purposes and where an employer has reasonable grounds to believe an employee is engaged in conduct that is criminal, violates the rights of the employer or coworkers, or creates a hostile work environment. Airports are also exempt.

Automated Employment Related Decision Technology (AEDT)

This new law, previously described in Connecticut Enacts new AI Transparency Law Requirements for Employers, affects how employers use generative artificial intelligence (AI) in employment-related decisions. Although employers do not need to follow the new law’s notification requirements until October 1, 2027, the law itself takes effect October 1 of this year, as do two of its provisions.  

  1. The law amends the Connecticut Fair Employment Practices Act, which prohibits protected class discrimination and harassment as well as retaliation, effective October 1, 2026, to state that an employer may not use reliance on AI as a defense to a claim brought for a violation of that Act, and authorizes the Commission on Human Rights and Opportunities and courts to consider “anti-bias testing or similar proactive efforts to avoid the discriminatory practice” used by an employer when analyzing claims involving AEDT.
  2. Where an employer is required by other laws to issue notice to employees of mass layoff, such as the federal WARN Act, the law requires employers to include in the notice whether AEDT was used in the decision related to the layoff.

Reasonable Accommodation Notice

This new law also amends the Connecticut Fair Employment Practices Act effective October 1, 2026. As of that date, employers are required to provide written notice to employees regarding their right to reasonable accommodation. Notice must be provided to: existing employees within 120 days of October 1, 2026 (Friday, September 29, 2026); all new employees when they commence employment; and any employee who notifies an employer of a disability within 10 days of that notification.

Lactation Breaks

Connecticut has long required employers to allow employees to express milk or breastfeed during existing meal or other breaks. The new law now requires employers to provide other reasonable lactation breaks in addition to an employee’s regularly scheduled breaks. All other requirements – a private area near an employee’s work location that is not a restroom and refrigeration – remain unchanged.

Expanded Ban on Employee Promissory Notes

Connecticut law prohibits employment promissory notes – any agreement by which an employee must repay an employer if the employee ends their employment before a prescribed period. The law, as it has existed for many years, applies only to employers with 25 or more employees. Effective October 1, 2026, the law is expanded to all employers with 1 or more employees. The law does not apply to requirements that an employee repay other employee loans, sabbatical terms, and programs that are agreed to in a collective bargaining agreement.

The Bottom Line

Connecticut employers beware, because change is coming. In consideration of the breadth and substance of the October 1 changes, Connecticut employers should begin proactively reviewing their employment policies and procedures to ensure compliance with all newly enacted requirements. Failing to follow the newly enacted requirements could result in civil fines and penalties.

If you have any questions regarding this Alert, please contact the author, Johanna Zelman, Managing Partner for our Hartford office at jzelman@fordharrison.com. Of course, you can also contact the FordHarrison attorney with whom you usually work.