AI Regulation Tracker / New law

Connecticut's CART Act Bars AI From Being an Employer's Defense to a Discrimination Claim and Forces AI Disclosure on Mass Layoffs

Regulatory summary: The Connecticut Artificial Intelligence Responsibility and Transparency Act, enacted as Public Act 26-15 (Substitute Senate Bill 5, titled An Act Concerning Online Safety) and approved by Governor Ned Lamont on May 27, 2026 according to the Public Act text, is law with staggered effective dates. Its two lead employment provisions took effect on October 1, 2026: the AEDT discrimination-defense change in section 13 and the WARN-notice AI disclosure in section 26.

Public Act 26-15, approved May 27, 2026, tells Connecticut employers that using an automated employment-related decision technology is not a defense to a complaint alleging a discriminatory practice in violation of section 46a-60(b)(1), and requires employers serving WARN notices to disclose whether the layoffs relate to AI. Those two provisions took effect October 1, 2026. Broader AEDT notice rules and AI companion rules follow later.

Primary source

By Anthony Guerriero, Founder, The Leveraged Years · Published July 9, 2026 · Last updated October 2, 2026

Connecticut's CART Act Bars AI From Being an Employer's Defense to a Discrimination Claim and Forces AI Disclosure on Mass Layoffs regulation briefing

The Leveraged Years AI Regulation Tracker

Update, 2 October 2026

1 October 2026 is the date Public Act 26-15 itself gives for the two employment provisions this article leads with. Section 13 amends subdivision (1) of section 46a-60(b), the employment-discrimination provision, so that the use of an automated employment-related decision technology "shall not be a defense against a complaint alleging a discriminatory practice in violation of this subdivision". The same passage says the commission or court "may consider" evidence of anti-bias testing or similar proactive efforts. Section 13 is marked "Effective October 1, 2026". So is section 26, under which each employer serving a federal WARN notice on the Labor Department "shall disclose" whether the layoffs are related to its use of artificial intelligence or another technological change, in a form and manner the Labor Commissioner prescribes.

Sections 7 to 12 carry the same 1 October 2026 date, but the duties in sections 8 and 9 are framed around technology deployed on or after 1 October 2027, a date that has not arrived. Section 8 limits the developer's information duty to technology advertised, marketed, configured, contracted for, sold or licensed to materially influence an employment-related decision. Section 9's plain-language disclosure covers technology intended to interact with employees or applicants, with no disclosure required where a reasonable person would deem the interaction obvious. The act defines "Deploy" as putting the technology into use; it does not say "first deployed", and this desk has not resolved how the 2027 trigger applies to a tool already in use before that date.

Two sections of PA 26-15 have been repealed. Section 67 of Public Act 26-100 reads "Sections 1 and 33 of public act 26-15 are repealed." and is marked effective from passage; PA 26-100 records the Governor's approval on 2 June 2026. Section 1 of PA 26-15 was the subscription-based AI provider disclosure rule, marked effective 1 October 2026. Section 33, marked effective 1 July 2027, concerned a Department of Consumer Protection pilot program for independent verification organizations assessing AI models. Neither is among the provisions this article describes. This desk reports the two texts as they read and has not traced the repeal further.

The PA 26-15 text on file also records the Governor's action as "Approved May 27, 2026". This article gave 2 June 2026 as the signing date. That date is not in the PA 26-15 text; 2 June 2026 is the approval date recorded on PA 26-100. We have not opened the Governor's release cited as corroboration.

Key takeaways

Connecticut moved from having no comprehensive AI statute to enacting one of the broadest in the country. For employers the two provisions in effect since October 1, 2026 are that using an AEDT is not a defense to a complaint alleging a discriminatory practice in violation of section 46a-60(b)(1), and that section 26 requires an employer serving a federal WARN notice to disclose to the Labor Department whether the layoffs relate to AI or another technological change. The act separately builds an AEDT transparency regime (developer-to-deployer information sharing plus plain-language notices to workers), AI companion safety duties including a suicide and self-harm protocol and a 9-8-8 referral, generative AI content provenance duties for large providers, frontier developer whistleblower protections, and state-agency AI governance.
HR leaders and talent-acquisition teams using AI screening, ranking, or scoring tools; in-house and employment counsel; executives signing off on reductions in force; HR technology vendors selling into Connecticut; AI companion and chatbot operators; healthcare organizations relying on the clinical-support carve-out; and compliance officers at large generative AI providers.
Status: Approved by the Governor May 27, 2026, as recorded on the Public Act.
Sections 13 and 26 have applied since October 1, 2026. As suggested preparation rather than a statutory duty: map which AI systems influence hiring, promotion, discipline, or discharge of Connecticut workers; keep anti-bias testing evidence, which the commission or court may consider; and add a layoff-process step that records whether the layoffs relate to AI, for the section 26 disclosure.

Regulatory Briefing

The short version

Bottom line. The Connecticut Artificial Intelligence Responsibility and Transparency Act, enacted as Public Act 26-15 (Substitute Senate Bill 5, titled An Act Concerning Online Safety) and approved by Governor Ned Lamont on May 27, 2026 according to the Public Act text, is law with staggered effective dates. Its two lead employment provisions took effect on October 1, 2026: the AEDT discrimination-defense change in section 13 and the WARN-notice AI disclosure in section 26.

Current status. Approved by the Governor May 27, 2026, as recorded on the Public Act. In force on staggered dates. Sections 1 and 33 were repealed by section 67 of Public Act 26-100 (effective from passage; PA 26-100 approved 2 June 2026). The employment provisions in sections 13 and 26 took effect on 1 October 2026.

Effective date. Section 13 discrimination-defense change and Section 26 mass-layoff AI disclosure took effect October 1, 2026. Sections 1 and 33 were repealed by PA 26-100, section 67. AEDT developer and deployer notice duties (Sections 7 to 12) take effect October 1, 2026 and apply to technologies deployed on or after October 1, 2027. AI companion rules (Sections 4 to 6) take effect January 1, 2027. The minors platform provisions (Section 39) take effect January 1, 2028.

Bindingness: Enacted state law (public act), in force on staggered dates. Public Act 26-15 is a signed statute, not a bill or a proposal. It amends the Connecticut General Statutes and creates new sections. It is binding once each section's effective date arrives. The earliest employment provisions are operative October 1, 2026. Enforcement is by the Attorney General as an unfair or deceptive trade practice under section 42-110b of the general statutes, and the act expressly provides no private right of action for its new AI sections.
Scope: Employers, AEDT developers and deployers doing business in Connecticut, operators of AI companions, large-user generative AI providers, frontier model developers, and state agencies. The employment provisions reach any employer covered by the state discrimination statute and any employer that files a federal WARN Act notice for Connecticut layoffs. The AEDT notice duties reach persons doing business in the state who develop or deploy technology that is a substantial factor in employment-related decisions. A targeted healthcare carve-out excludes certain clinical-support AI from the companion rules.
What Changed: Connecticut moved from having no comprehensive AI statute to enacting one of the broadest in the country. For employers the two provisions in effect since October 1, 2026 are that using an AEDT is not a defense to a complaint alleging a discriminatory practice in violation of section 46a-60(b)(1), and that section 26 requires an employer serving a federal WARN notice to disclose to the Labor Department whether the layoffs relate to AI or another technological change. The act separately builds an AEDT transparency regime (developer-to-deployer information sharing plus plain-language notices to workers), AI companion safety duties including a suicide and self-harm protocol and a 9-8-8 referral, generative AI content provenance duties for large providers, frontier developer whistleblower protections, and state-agency AI governance.
Who This Affects: HR leaders and talent-acquisition teams using AI screening, ranking, or scoring tools; in-house and employment counsel; executives signing off on reductions in force; HR technology vendors selling into Connecticut; AI companion and chatbot operators; healthcare organizations relying on the clinical-support carve-out; and compliance officers at large generative AI providers.
Current Status: Approved by the Governor May 27, 2026, as recorded on the Public Act. In force on staggered dates. Sections 1 and 33 were repealed by section 67 of Public Act 26-100 (effective from passage; PA 26-100 approved 2 June 2026). The employment provisions in sections 13 and 26 took effect on 1 October 2026.
Effective Date: Section 13 discrimination-defense change and Section 26 mass-layoff AI disclosure took effect October 1, 2026. Sections 1 and 33 were repealed by PA 26-100, section 67. AEDT developer and deployer notice duties (Sections 7 to 12) take effect October 1, 2026 and apply to technologies deployed on or after October 1, 2027. AI companion rules (Sections 4 to 6) take effect January 1, 2027. The minors platform provisions (Section 39) take effect January 1, 2028.
Primary Source: https://www.cga.ct.gov/2026/act/pa/pdf/2026PA-00015-R00SB-00005-PA.pdf
Secondary Analysis: Office of Governor Ned Lamont press release (June 2, 2026); Ropes and Gray, Connecticut Enacts Sweeping AI Law Covering Employment, Healthcare, and Online Safety (June 2026); Future of Privacy Forum, SB 5 in Five (June 2026).
Workflow Impact: Suggested preparation, not statutory text: HR teams can inventory AI tools that touch employment decisions and keep anti-bias testing records, which the commission or court may consider under section 13. The statutory duties are narrower. Since October 1, 2026, section 26 requires an employer serving a federal WARN notice on the Labor Department to disclose whether the layoffs relate to AI or another technological change. The worker-facing disclosure in section 9 applies only to deployments on or after October 1, 2027, a date that has not arrived, and not where a reasonable person would deem the interaction obvious. Vendor contracts need clauses allocating the developer and deployer duties under Sections 8 to 10.
Operational Next Step: Sections 13 and 26 have applied since October 1, 2026. As suggested preparation rather than a statutory duty: map which AI systems influence hiring, promotion, discipline, or discharge of Connecticut workers; keep anti-bias testing evidence, which the commission or court may consider; and add a layoff-process step that records whether the layoffs relate to AI, for the section 26 disclosure.
Last Verified: July 10, 2026

Date	Jurisdiction	Rule	Affected professionals	Status or effective date
2026-07-09	United States (Connecticut)	Connecticut moved from having no comprehensive AI statute to enacting one of the broadest in the country. For employers the two provisions in effect since October 1, 2026 are that using an AEDT is not a defense to a complaint alleging a discriminatory practice in violation of section 46a-60(b)(1), and that section 26 requires an employer serving a federal WARN notice to disclose to the Labor Department whether the layoffs relate to AI or another technological change. The act separately builds an AEDT transparency regime (developer-to-deployer information sharing plus plain-language notices to workers), AI companion safety duties including a suicide and self-harm protocol and a 9-8-8 referral, generative AI content provenance duties for large providers, frontier developer whistleblower protections, and state-agency AI governance.	HR leaders and talent-acquisition teams using AI screening, ranking, or scoring tools; in-house and employment counsel; executives signing off on reductions in force; HR technology vendors selling into Connecticut; AI companion and chatbot operators; healthcare organizations relying on the clinical-support carve-out; and compliance officers at large generative AI providers.	Approved by the Governor May 27, 2026, as recorded on the Public Act. In force on staggered dates. Sections 1 and 33 were repealed by section 67 of Public Act 26-100 (effective from passage; PA 26-100 approved 2 June 2026). The employment provisions in sections 13 and 26 took effect on 1 October 2026.

Source File

Instrument: Public Act No. 26-15, Substitute Senate Bill No. 5, An Act Concerning Online Safety (Connecticut Artificial Intelligence Responsibility and Transparency Act)
Authority: Connecticut General Assembly; signed by Governor Ned Lamont
Date: Approved May 27, 2026 (per the Public Act text); staggered effective dates, the first employment provisions in effect since October 1, 2026; sections 1 and 33 repealed by PA 26-100, section 67
Citation: 2026 Conn. Pub. Act No. 26-15 (Sub. S.B. 5), Sections 2, 4-15, 26, 38, 39
Primary Source: https://www.cga.ct.gov/2026/act/pa/pdf/2026PA-00015-R00SB-00005-PA.pdf
Corroboration: Office of Governor Ned Lamont, Governor Lamont Signs Legislation Establishing Youth Online Safety Protections, Regulations Over Artificial Intelligence (June 2, 2026); Ropes and Gray, Connecticut Enacts Sweeping AI Law Covering Employment, Healthcare, and Online Safety (June 2026); Future of Privacy Forum, SB 5 in Five (June 2026).

Frequently Asked Questions

Is the CART Act in force now?

It is enacted and partly in force. The Public Act records the Governor's approval on May 27, 2026. Its provisions take effect on staggered dates. The two key employment provisions, the change making AEDT use no defense to a complaint under section 46a-60(b)(1) and the mass-layoff AI disclosure, took effect October 1, 2026. Sections 1 and 33 were repealed by PA 26-100, section 67.

Does the act ban employers from using AI in hiring?

No. It does not prohibit AEDTs. It provides that using one is not a defense to a complaint alleging a discriminatory practice in violation of section 46a-60(b)(1), provides for worker-facing disclosures for tools intended to interact with workers that are deployed on or after October 1, 2027 (not yet operative), and lets the commission or court consider anti-bias testing evidence.

When exactly do the AEDT notice duties apply to my tools?

Sections 8 to 12 take effect October 1, 2026, but the developer and deployer notice duties apply to automated employment-related decision technologies deployed on or after October 1, 2027.

Can an employee sue us directly under the act?

Not under the new AI sections. Enforcement runs solely through the Attorney General as an unfair or deceptive trade practice under section 42-110b. The act states it provides no private right of action for those sections. Underlying discrimination claims still proceed through existing law.

What is the most urgent employer step now that sections 13 and 26 are in effect?

Inventory every AI system that influences hiring, promotion, discipline, or discharge of Connecticut workers, gather current anti-bias testing evidence, and add a step to your layoff process that records whether AI informed the decision for the required Labor Department disclosure.