AI Policy

Connecticut Just Made Your Hiring Software a Disclosure Obligation

Connecticut's new CART Act turns everyday hiring and HR software into regulated technology, with disclosure duties and real liability for employers.

By Harrison Painter June 6, 2026 Updated June 6, 2026 7 min read

In late May 2026, Governor Ned Lamont signed Senate Bill 5 into law as Public Act 26-15, the Connecticut Artificial Intelligence Responsibility and Transparency Act, or the CART Act, and his office announced it publicly on June 2. It is an omnibus law, which means it covers a lot of ground at once: consumer protection, healthcare, online safety for kids, government use, and the one most leaders will feel first, employment.

If you run a team in Connecticut, or you hire people who work there, the part to read closely is the employment section. It reaches the everyday software many managers already use without thinking of it as "AI" at all.

What the law actually regulates

The CART Act creates a category called "automated employment-related decision technology," or AEDT. The definition is broad: any technology that processes personal data and produces an output that is a substantial factor in making, or materially influences, an employment-related decision.

Read that again, because the scope surprises people. Law firms parsing the enacted text point out that this definition is wide enough to cover tools most companies already run:

  • Third-party hiring platforms
  • Resume-screening software
  • Assessment tools
  • Performance-analytics dashboards

The statute does carve out some decisions: workplace health and safety, scheduling, and productivity monitoring, along with nonmaterial changes to hours or assignments. So a scheduling or workforce-management tool is not automatically covered. It can still be relevant if its output becomes a substantial factor in a covered decision like discipline, discharge, promotion, or a material change in employment terms.

You do not have to be building models to be covered. You only have to be using a tool whose output meaningfully shapes who gets hired, promoted, or let go.

The disclosure duty

When an AEDT's output is making, or is a substantial factor in making, an employment-related decision about someone, employers have to disclose that the technology is in use. That applies to both employees and applicants. The person on the other side of the decision gets to know a machine helped make it.

The shield that no longer works

One change reshapes the risk for any company buying these tools. The CART Act amends the Connecticut Fair Employment Practices Act so that using an AEDT is not a defense to a discrimination claim. A court may consider an employer's anti-bias testing efforts as a mitigating factor, but "the software flagged this candidate" is no longer an answer that ends the conversation.

Employers cannot offload discrimination liability onto the tool or the vendor. Vendor contracts may help with compliance duties, but the employer still has to stand behind its own employment decisions.

Layoffs tied to AI get disclosed

Starting October 1, 2026, employers filing a federal WARN Act mass-layoff notice have to tell the Connecticut Department of Labor whether the layoffs are related to the employer's use of AI or other technological changes. A quiet efficiency decision becomes a disclosed, on-the-record one.

The timeline to know

The CART Act phases in over more than a year, so the obligations do not all arrive at once.

  • October 1, 2026: The AEDT statutory framework takes effect, including the definitions, the enforcement structure, trade-secret limits, and the amendment that removes AEDT use as a defense to discrimination. The WARN-notice AI-disclosure requirement begins the same day. Frontier-developer whistleblower protections also start.
  • January 1, 2027: The framework for AI companions (chatbots) takes effect, and large frontier developers must implement anonymous internal reporting channels.
  • October 1, 2027: The principal AEDT compliance obligations apply, including interaction disclosures and pre-decision written notices.
Oct. 1, 2026

The AEDT framework, the removal of AI use as a defense to discrimination, and the federal WARN Act AI-disclosure requirement all take effect on this date.

Source: Public Act 26-15, 2026

So the structure and the discrimination change take effect first, in fall 2026. The detailed notice mechanics for employers follow a year later, in fall 2027. That stagger gives leaders time to get ready, if they start now.

The parts beyond employment

The employment section is the one most businesses will feel, but the CART Act is wider than that.

It regulates operators of AI companions, meaning relationship-oriented systems that hold a human-like conversation over time. The law carves out narrow, task-specific tools built for a discrete topic or function, so many ordinary business and customer-support chatbots fall outside it, unless the tool's main job is discussing mental health. Operators of covered companions have to tell users they are interacting with AI and not a real person. They also have to make reasonable efforts to detect expressions of suicidal ideation or self-harm and have a protocol to respond with appropriate resources.

It places catastrophic-risk obligations on "frontier developers," defined as those training a foundation model above a compute threshold of 10^26 floating-point operations. A "large frontier developer" is one with at least $500 million in annual gross revenue, aggregated with affiliates under common control, in the preceding calendar year. Those obligations cover risks like enabling chemical, biological, radiological, or nuclear threats and large-scale cyberattacks. The Act also requires AI-generated synthetic content to be detectable.

It builds public infrastructure too. The law creates an Artificial Intelligence Policy Office and an "AI Academy" offering courses and resources, and it folds AI topics into teacher certification programs. The AI Academy connects to residents through partnerships with the Connecticut Department of Housing, the Department of Labor, and the Secretary of the State.

And it adds youth online-safety rules: social-media companies are barred from exposing minors to addictive algorithms and notifications without parental consent, parents get tools to set time limits, and warning signs have to block children from sensitive content.

The law was a collaborative effort between Governor Lamont, Attorney General William Tong, and State Senator James Maroney of Milford, co-chair of the legislature's General Law Committee. Tong, in announcing the law, said Connecticut is done waiting for the tech industry and Washington to act on behalf of families. A spokesperson for Governor Lamont put the employment piece in simple terms: workers should benefit from greater efficiency on the job without fearing discrimination or displacement.

What this means if you feel behind on AI

The people most exposed here are not AI engineers. They are managers, HR leaders, and small-business owners who quietly adopted a resume screener, a scheduling tool, or a performance dashboard because it saved time. Connecticut just said those everyday tools become regulated technology the moment their output is a substantial factor in a personnel decision.

This is the practical face of the multi-state rulebook leaders keep hearing about. Connecticut now joins Colorado and others, and an employer operating across state lines has to know which AI-in-hiring rules apply where.

There is a throughline here to how we think about getting good with AI. In the 7 Levels of AI Proficiency, the early levels are about awareness and basic use, and the higher levels are about understanding what a system is doing on your behalf and being able to govern it. The CART Act rewards the second kind of knowledge. Proficiency goes past knowing how to prompt a tool. It means knowing what the tool decides for you, and being able to disclose it, defend it, and stand behind it. "We did not realize it counted as AI" is about to become an expensive sentence in Connecticut.

Your next step

Pull a short inventory of the software your team uses to screen, assess, schedule, or evaluate people. For each one, write down a plain answer to a single question: does this tool's output substantially influence a hiring, firing, promotion, or discipline decision? That list is the starting point for any disclosure or governance work, and it is something you can build this week without waiting on a vendor or a lawyer to hand it to you.

Related reading: Level 6: Admiral.

Sources

  1. Public Act 26-15 / Substitute Senate Bill No. 5 (official statute text)
  2. Governor Lamont Signs Legislation Establishing Youth Online Safety Protections (Office of the Governor)
  3. Connecticut's Lamont Signs AI Law With Employer Notice Mandate (Bloomberg Law)
  4. Connecticut Enacts Sweeping AI Law Covering Employment, Healthcare, and Online Safety (Ropes & Gray)
  5. Connecticut Employers Need to Prepare for New Workplace AI Law (Fisher Phillips)
  6. Connecticut Passes Law Significantly Regulating Use of AI in Employment (Littler)
  7. New Connecticut Law Restricts Employer AI Use, Mandates Notice for AI-Caused RIFs (Ogletree Deakins)
  8. Connecticut Takes Aim at AI in Employment Decisions: SB 5 (ArentFox Schiff)
  9. SB 5 in Five: What to Know About Connecticut's New AI Law (Future of Privacy Forum)
  10. TCAI Bill Guide: SB 5, Connecticut's Omnibus AI and Online Safety Bill (Transparency Coalition)
  11. CT AI Transparency, Safety, and Consumer Protection Law (Davis Wright Tremaine)

Frequently Asked Questions

Does this only apply to companies based in Connecticut?

The employment provisions turn on decisions about employees and applicants connected to Connecticut. If you hire people who work there, treat the law as relevant and confirm the specifics with counsel.

Does the law ban AI in hiring?

No. It does not prohibit AEDT use. It requires disclosure when the technology substantially shapes an employment decision, and it removes the ability to use AEDT use as a defense to a discrimination claim.

When do the employer notice obligations actually start?

The framework and the discrimination amendment take effect October 1, 2026. The principal AEDT compliance obligations, including interaction disclosures and pre-decision written notices, apply October 1, 2027.

Is a scheduling app really covered?

Not just because it schedules shifts. The statute appears to exclude scheduling and planning decisions outright. But if the tool's output becomes a substantial factor in a covered employment decision, like discipline, discharge, promotion, or a material change in employment terms, it may still need legal review.

Harrison Painter, Executive AI Advisor
Harrison Painter
Executive AI Advisor. Founder, LaunchReady.ai and AI Law Tracker.

Harrison is an Indiana AI Advisor who helps business owners and executives get their time back by building AI systems that run the work for them. Nearly 20 years in business and author of You Have Already Been Replaced by AI. Creator of The 7 Levels of AI Proficiency.

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