States are moving faster on AI regulation than Congress, and the obligations now landing on employers are concrete.

Connecticut's new law is one of the most detailed yet, and its clock is already running.

Frances M. Green, Of Counsel in the Employment, Labor & Workforce Management practice of Epstein Becker Green, authored "Connecticut Enacts Comprehensive AI Law With New Employer Obligations" in Databird Business Journal.

Connecticut's Public Act No. 26-15, signed in May 2026, governs automated employment-related decision technology, meaning any AI-driven tool that meaningfully influences hiring, promotion, discipline, or separation decisions.

Three staggered deadlines define what employers must do and when: developer and deployer duty-allocation provisions and the new WARN Act AI-disclosure requirement both take effect October 1, 2026; full deployer obligations, including written pre-decision notice and interaction disclosure, follow on October 1, 2027. Frances also addresses Connecticut's amendment confirming that using AI is not a defense to a discrimination claim, and notes that documented bias-testing can serve as a mitigating factor.

Given the staggered runway, employers with Connecticut operations or applicants may wish to begin now to:

  • Inventory AI and automated tools used to make or materially influence employment decisions, distinguishing covered AEDT from carved-out utilities and monitoring functions.
  • Review and build out interaction-disclosure and pre-decision notice procedures against the October 1, 2027, deadline, including the specific content elements the Act requires.
  • Assess whether bias auditing of covered tools is warranted to mitigate disparate-impact exposure, and document the methodology, scope, and results—evidence the statute expressly permits as mitigation.
  • Examine developer and vendor contracts to confirm that the information needed for deployer notices will be furnished, and to allocate compliance responsibility and risk.
  • Integrate the WARN AI-disclosure question into RIF and layoff-planning workflows ahead of October 1, 2026.
  • Confirm whether an AI governance policy is in place and, if not, consider implementing one as a documented foundation for compliance.

Epstein Becker Green Staff Attorney Ann W. Parks contributed to the preparation of this article.

Get in Touch

To learn more about this topic, contact Frances Green at fgreen@ebglaw.com.

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