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Connecticut Public Act 26-100, section 46, in force from October 1, 2026, bars generative AI subscription providers with more than one million monthly users from starting, renewing or charging for a consumer subscription without a written key-terms notice and the consumer's written acceptance
Section 46 is binding Connecticut law from October 1, 2026, and it reaches only providers that create, code or otherwise produce a generative AI system with more than one million monthly users and offer it to consumers by subscription. It follows the repeal of an earlier, broader subscription provision in PA 26-15 before that provision's scheduled October 1 start, so a team that scoped its work to the May text may have scoped the wrong rule.
Bottom line: Section 46 is a binding statute and is in force. Section 46 of Public Act 26-100 is marked "(Effective October 1, 2026)" in the Act, which the Governor approved on June 2, 2026. Other sections of the same Act carry other dates, including some effective from passage and section 47, effective October 1, 2027.
Who this affects: Executives, general counsel and consumer-compliance, billing and product teams at companies that build generative AI systems with more than one million users per month and sell personal-use access to Connecticut consumers by subscription.
Issue date: Public Act 26-100 was approved June 2, 2026. Section 46 is effective October 1, 2026. Section 67, which repeals section 1 of PA 26-15, is marked effective from passage.
What changed: Since October 1, 2026, a covered provider may not enter into, renew or collect a fee for a Connecticut consumer subscription unless it has given the consumer a written notice of the key terms and the consumer has given the provider a written notice accepting them. The Act lists what the provider's notice has to contain.
Analysis: On our reading, the more useful fact for a compliance team is the repeal. PA 26-15 section 1, approved May 27, 2026, would have applied a near-identical notice duty to any provider of artificial intelligence technology by subscription from October 1, 2026. PA 26-100 repealed that section before that date, and its own section 46 adds a one-million-user threshold, a creator requirement and a narrower generative AI definition.
Primary sources: Connecticut Public Act No. 26-100 (Substitute House Bill No. 5222), full text PDF, Connecticut General Assembly · Connecticut Public Act No. 26-15 (Substitute Senate Bill No. 5), full text PDF, Connecticut General Assembly
- Instrument (EN)
- Public Act No. 26-100, An Act Concerning Consumer Protection, Cannabis, Data Privacy, Fire Inspections, Criminal Mischief and Artificial Intelligence (Substitute House Bill No. 5222), section 46
- Authority
- Connecticut General Assembly; approved by the Governor June 2, 2026. Enforcement of section 46 rests solely with the Attorney General
- Jurisdiction
- Connecticut, United States
- Status
- Enacted. Section 46 effective October 1, 2026
- Bindingness
- Binding statute. A violation of section 46(b) is an unfair or deceptive trade practice under section 42-110b(a) of the general statutes; the section says it creates no private right of action
- Issue date / next deadline
- Approved June 2, 2026; section 46 effective October 1, 2026. Section 47 of the same Act, a separate pilot program, is effective October 1, 2027
- Coverage threshold
- A person doing business in the state that creates, codes or otherwise produces a generative AI system with more than one million users per month, publicly accessible to consumers for personal use, and provides it by subscription. Government agencies are excluded
- Related repeal
- Section 67 of PA 26-100 repeals sections 1 and 33 of PA 26-15, effective from passage
- Primary source
- https://www.cga.ct.gov/2026/act/Pa/pdf/2026PA-00100-R00HB-05222-PA.PDF
Who counts as a subscription-based provider under section 46?
Under section 46(a)(5), in force since October 1, 2026, a subscription-based provider is a person doing business in the state who "creates, codes or otherwise produces" a generative artificial intelligence system that "has more than one million users per month" and "is publicly accessible to consumers for personal use", and who provides or offers that system to a consumer under a subscription. The same subdivision says the term "does not include any federal, state or local government agency". Every part of that definition has to be met for section 46 to apply.
A subscription means an agreement under which the provider offers the system to the consumer for "a fee, remuneration or compensation of any kind" from the consumer. "Consumer" takes its meaning from section 42-515 of the general statutes, which we did not open.
The definition of the technology narrows the scope further. Section 46(a)(2) says a generative artificial intelligence system "means any technology that uses machine learning to generate images, audio or video" and includes, but is not limited to, systems using deep learning, natural language processing or comparable techniques. The text does not say in terms whether a service that generates only text falls inside that definition. We do not resolve that question here, and a text-only provider near the threshold has reason to take its own advice on it.
Two further gaps sit in the text. Section 46 does not define "users", and it does not say whether the one million monthly users are counted in Connecticut or everywhere. On our reading of the creator requirement, a business that resells or embeds another company's model without itself creating, coding or producing it is not caught by subdivision (5)(A)(i), but the section does not address that case directly.
What does a covered provider have to do before charging a consumer?
Since October 1, 2026, section 46(b)(1) provides that "No subscription-based provider shall enter into or renew a subscription with a consumer, or collect any fee, remuneration or compensation of any kind from a consumer for an initial subscription or subscription renewal, unless" two conditions are met, one written notice running in each direction.
The first is a provider notice: "a written notice disclosing the key terms and conditions of the subscription". The second runs the other way. The consumer has to have given the provider "a written notice disclosing that the consumer has accepted the key terms and conditions of the subscription".
The second condition is easy to overlook in a checkout design. A disclosure page alone does not satisfy section 46 on its face; the text also requires a written acceptance from the consumer before the provider enters, renews or collects. The Act does not say what form that written notice from the consumer can take, and we make no claim about whether a click-through or checkbox flow qualifies.
What has to be in the provider's notice?
Under section 46(b)(2), in force since October 1, 2026, the notice for an initial subscription has to set forth "material information that is sufficient to enable a reasonable consumer to decide whether to purchase or maintain the subscription", including at least the two items below.
First, any quantitative or qualitative limitations the provider may impose under the subscription, "including, but not limited to, any limitations on tokens, images generated or modified or transcription services", and including limitations the provider may impose in response to the consumer's conduct. Second, whether the provider has discretion to limit or eliminate the consumer's access to, or reduce the quantity or quality of, any functionality of the system offered under the subscription.
For a renewal, the notice covers change. It has to set forth any of those limitations that will be imposed for the first time in the renewal term, or that applied in the preceding term but have been modified, and any of that discretion the provider will be able to exercise for the first time, or that existed in the preceding term but has been modified.
How is section 46 enforced?
The Attorney General alone enforces it, through the state's unfair trade practices law. Section 46(c) says a violation of subsection (b) "shall constitute an unfair or deceptive trade practice" for the purposes of section 42-110b(a) of the general statutes and is "enforced solely by the Attorney General".
The same subsection says section 42-110g of the general statutes does not apply to such a violation, and that "Nothing in this section shall be construed as providing the basis for a private right of action". We did not open section 42-110g and do not describe what it would otherwise provide. Section 46 sets no penalty amount of its own.
How does this relate to the subscription rule in PA 26-15?
PA 26-15, the online safety Act approved May 27, 2026, contained its own AI subscription section. Its section 1, marked "(Effective October 1, 2026)" but repealed by PA 26-100 section 67 before that date arrived, would have imposed the same two-notice structure, the same notice contents in substance and the same Attorney General enforcement, but on any "person doing business in the state who provides, or offers to provide, an artificial intelligence technology to a consumer pursuant to a subscription". Its repealed text defined a consumer as "an individual who is a resident of this state", and it set no user threshold and no government exclusion.
PA 26-100 then deals with that section directly. Its section 67 reads: "Sections 1 and 33 of public act 26-15 are repealed", effective from passage. Section 33 of PA 26-15 was a Department of Consumer Protection pilot program for independent verification of AI models, effective July 1, 2027; section 47 of PA 26-100 contains a pilot program with the same definitions, effective October 1, 2027.
Read together, and on our reading only, the two texts indicate that the broad PA 26-15 version was repealed before its own October 1 start date and that section 46 is the operative Connecticut subscription-notice provision. Neither Act says in terms that section 46 replaces PA 26-15 section 1, and we did not check how the Legislative Commissioners codified either section. Our earlier coverage of PA 26-15 is linked below; readers relying on it for the subscription rule should read it against section 67.
What we did not verify
What we opened: the full text of Public Act No. 26-100 as published by the Connecticut General Assembly (PDF, 154 pages), extracted to text. We read section 46 at pages 81 to 83, the start of section 47 at pages 83 and 84, section 67 at page 153 and the Governor's action at page 154. We also opened the full text of Public Act No. 26-15 and read section 1, the start of section 33 and the Governor's action at page 74.
What we did not open: sections 42-515, 42-110b and 42-110g of the Connecticut general statutes, any Attorney General guidance or statement on section 46, any legislative history, bill analysis or fiscal note for House Bill 5222, and any codified version of either Act. We did not read every section of PA 26-100.
What we refuse to claim: we do not say which companies meet the one-million-user threshold, whether text-only services are covered, how users are counted, or what form of written consumer acceptance satisfies section 46(b)(1)(B). We do not say every provision of PA 26-100 took effect October 1, 2026. We make no claim that this is the first or only law of its kind, and we do not predict how the Attorney General would enforce it.
Quotations are copied from the Act text with line breaks joined and no words changed.
Informational analysis for working professionals, not legal advice. Confirm how any rule applies to your situation with qualified counsel.
A generative AI business that may sit above one million monthly users and sells personal-use subscriptions in Connecticut needs two records for every initial subscription and renewal from October 1, 2026: the key-terms notice it sent, and the consumer's written acceptance received before any charge. Teams that scoped their work to PA 26-15 section 1 should re-scope it against section 46, since PA 26-100 repeals the earlier text.
Source File
https://www.cga.ct.gov/2026/act/Pa/pdf/2026PA-00100-R00HB-05222-PA.PDF
Open Public Act No. 26-100 on cga.ct.gov and confirm four things: the "(Effective October 1, 2026)" marker on section 46 at page 81, the provider definition and government exclusion in section 46(a)(5), the two written-notice conditions and notice contents in section 46(b) at pages 82 and 83, and the repeal of sections 1 and 33 of PA 26-15 in section 67 at page 153.
The consumer has provided to the subscription-based provider a written notice disclosing that the consumer has accepted the key terms and conditions of the subscription. ยท Connecticut Public Act No. 26-100, section 46(b)(1)(B), approved June 2, 2026, effective October 1, 2026
FAQ
Is section 46 of PA 26-100 in force?
Yes. The Act marks section 46 "(Effective October 1, 2026)", and the Governor approved the Act on June 2, 2026. Other sections of PA 26-100 have different effective dates, so the date applies to section 46, not to the whole Act.
Which providers does it cover?
A person doing business in Connecticut that creates, codes or otherwise produces a generative AI system with more than one million users per month that is publicly accessible to consumers for personal use, and provides it by subscription. Federal, state and local government agencies are excluded.
Is a disclosure to the consumer enough?
No. Section 46(b)(1) requires both a written notice of key terms from the provider and a written notice from the consumer accepting those terms before the provider enters into, renews or charges for a subscription.
Does PA 26-15 still impose its own subscription notice rule?
PA 26-15 section 1 would have applied a broader version, covering any AI technology provided by subscription, from October 1, 2026. Section 67 of PA 26-100 repeals sections 1 and 33 of PA 26-15, effective from passage. We did not check the codified statutes.
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