In late May 2026, Connecticut Governor Ned Lamont signed the Connecticut Artificial Intelligence Responsibility & Transparency Act (the "Act"). The Act is comprehensive and regulates many different areas beyond employment, such as consumer and companion chatbots, frontier-model developers, generative-AI content provenance, and online platforms used by minors.

But first – let’s focus on the law’s requirements related to "automated employment-related decision technology", the amendments to the state's anti-discrimination statutes, and expansion of disclosure obligations under Connecticut's version of the federal WARN Act.

Below we – summarize the Act's employment-related requirements, its enforcement scheme, and the practical steps employers should take soon to ensure compliance.

What the Act Covers

The Act regulates "Automated Employment-Related Decision Technology" ("AEDT"), defined as any technology that processes personal data and generates an output — such as a rank, score, classification, or recommendation—that is a substantial factor used to make or materially influence an employment-related decision.

Covered decisions include hiring, firing, promotion, discipline, renewal of employment, and selection of an individual for training. The Act defines "substantial factor" as something that "meaningfully alters" the outcome of a decision.

Employer & Developer Obligations

The Act divides its core disclosure obligations between developers and “deployers” (i.e., employers) of AEDT. These requirements apply to AEDT deployed in Connecticut on or after October 1, 2027.

Interaction Disclosure Requirement

A deployer that uses AEDT intended to interact with a job applicant or employee must disclose, in plain language, that the individual is interacting with such technology unless its “obvious” to a reasonable person.

Pre-Decision Written Notice to Applicants & Employees

Before using an AEDT, the deployer must provide the affected applicant or employee with written notice. The notice must disclose that AEDT has been deployed and the nature of the decision involved; the purpose and trade name of the technology; the categories of personal data analyzed and how that data will be assessed; the sources of that personal data; and contact information for the deployer.

Developer Duties

Developers must furnish deployers with all the information the deployers need to satisfy their disclosure and notice obligations, or the developers may assume those obligations by contract. This means developers must supply sufficient information about how their tools function, the data those tools use, the outputs they generate, and how those outputs may influence employment decisions.

This obligation is limited, however, to circumstances where the AEDT was advertised, marketed, configured, contracted for, sold, or licensed to materially influence an employment-related decision.

The Act includes a trade-secret safe harbor that permits developers and deployers to withhold protected information. A party invoking the safe harbor must nonetheless disclose what information is being withheld and specify the legal grounds for the withholding.

No Mandatory Bias Audits, But . . .

The Act does not specifically impose requirements to conduct bias audits or impact assessments of AEDT. However, the Act amends the Connecticut Fair Employment Practices Act to provide that, beginning October 1, 2026, an employer's use of AEDT is not a defense to a complaint alleging discriminatory practice. In other words, an employer cannot shield itself from liability for a discrimination claim by asserting that it relied on an AI tool.

At the same time, a court or the Connecticut Commission on Human Rights and Opportunities may consider evidence of anti-bias testing or "similar proactive efforts to avoid the discriminatory practice" as a mitigating factor. This amendment effectively rewards documented, proactive bias-mitigation efforts even though the Act does not independently require them.

Expanded WARN Act Disclosure

Beginning October 1, 2026, employers issuing written notices under Connecticut's Worker Adjustment and Retraining Notification ("WARN") Act for covered layoffs must disclose to the Connecticut Department of Labor whether the layoffs are related to the employer's use of AI or another technological change. This obligation will require human resources, legal, and operations teams to coordinate closely on the stated rationale for workforce reductions and to maintain documentation supporting that rationale.

Enforcement & Penalties

The AEDT-related provisions are enforceable exclusively by the Connecticut Attorney General, so there is no private right of action for plaintiffs’ attorneys to pursue. Also, for certain AEDT-related violations occurring on or before December 31, 2027, the Attorney General may exercise discretion to provide a cure period—reported as a 60-day opportunity to cure—before pursuing formal enforcement.

We’ll be monitoring closely to gauge whether these new provisions are aggressively enforced and to track the type of penalties assessed for non-compliance.

For Employers, Recommended Next Steps

Employers should begin by taking inventory of all automated tools used to rank, score, screen, or otherwise evaluate a Connecticut applicant or worker, and then identifying which of the Act's requirements apply.

Because deployers cannot comply without vendor cooperation, employers should ask each vendor in writing for the documentation the Act requires developers to provide and should confirm whether the vendor will supply that information or, better yet, assume the deployer's obligations by contract.

Employers should draft interaction disclosures and pre-decision written notices now, addressing the tool's purpose, trade name, data categories, and sources, how the data will be assessed, and deployer contact information, so that they are ready before October 1, 2027.

Because the "AI is not a defense" amendment and the WARN Act disclosure requirement take effect earlier, on October 1, 2026, employers should also coordinate across human resources, legal, and operations to document the rationale for any workforce reductions and to evaluate whether reductions are connected to AI or other technological change.

Finally, even though the Act does not mandate bias audits, employers should consider implementing bias testing and related proactive measures, both to reduce discrimination exposure and to preserve mitigating evidence that a court or the Commission on Human Rights and Opportunities may weigh in their favor.

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If you have questions or would like to discuss this or other laws that regulate the use of AI to make employment decisions, please contact your Silberman Law attorney or simply respond to this Alert.