Connecticut's automated hiring disclosure law takes effect. Candidates get AI notices in 2027

What the law does today, and what lands next year

Public Act 26-15, also known as the AI Responsibility and Transparency Act or CART Act, was signed by Governor Ned Lamont on May 27, 2026. The law has multiple provisions with staggered effective dates, and the provisions that take effect on October 1, 2026 are mostly framework language. They define what counts as an automated employment-related decision technology, who a developer or deployer is, and what counts as an employment-related decision, according to the text of the statute.

The statute defines automated employment-related decision technology, or AEDT, as any technology that processes personal data and uses computation to generate output, including a prediction, recommendation, classification, ranking, score or other information, that is a substantial factor in making or materially influencing an employment-related decision. The law carves out word processors, spreadsheets, antivirus software, spam filters, spellcheckers, calculators, databases and similar tools, along with non-material changes to job tasks, hours or work assignments, and decisions about workplace health and safety, scheduling, planning or productivity monitoring.

The same October 1, 2026 effective date brings in an amendment to the Connecticut Fair Employment Practices Act clarifying that the use of an automated employment-related decision technology shall not be a defense against a discrimination complaint under the act. Courts may still consider evidence of anti-bias testing or other proactive efforts when deciding damages, the statute says.

What employers must tell candidates starting October 1, 2027

The actual employer obligations do not kick in for another year. Starting October 1, 2027, any employer that deploys an automated employment decision tool to generate output used as a substantial factor in an employment decision concerning a Connecticut job applicant or employee must, before that decision is made, give the individual a written notice disclosing, in plain language, that the employer has deployed an automated employment-related decision technology.

The notice must include the purpose of the technology and the nature of the employment-related decision, the trade name of the tool, the categories of personal data the technology will analyze or process and how that data will be assessed in reaching a decision, the sources of that personal data, and contact information for the employer, according to Epstein Becker Green.

If the tool is used to interact with the applicant, for example through a chatbot or an automated interview screen, the employer must also tell the applicant, in plain language, that they are interacting with an automated system. The only carve-out is when a reasonable person would obviously know they are talking to AI. Programs that simply collect data for later human review, or decisions that will ultimately be made by a person, are not covered by the disclosure rule.

Trade secrets, enforcement, and the discrimination defense

The law protects trade secrets. An employer can withhold information that qualifies as a trade secret under Connecticut law, but if it does, it must tell the applicant that information is being withheld and explain the legal basis for the withholding. There is no private right of action under the disclosure framework. The Connecticut Attorney General has sole enforcement authority, and violations are treated as unfair or deceptive trade practices.

From October 1, 2026 through December 31, 2027, the Attorney General must give an employer a written notice of any alleged violation and a 60-day window to cure it before initiating a formal enforcement action, the statute says. After that transition period, the cure notice is no longer required.

For candidates, the practical effect is that by late 2027 they should be receiving plain-language disclosures every time an automated tool is used to screen, score, rank or otherwise influence a hiring decision, even before the decision is finalized.

What Connecticut employers should do in the next year

Employers using AI for employment-related purposes in Connecticut should treat October 1, 2027 as a hard deadline and the next twelve months as a runway, Epstein Becker Green wrote in its analysis for clients. That means auditing any AI systems currently deployed in hiring, performance management or other workforce decisions, and examining whether existing notices adequately tell candidates and employees when such tools are involved.

Organizations should also weigh whether an independent bias audit is warranted for AI-driven employment workflows, particularly to reduce exposure to disparate impact claims under Connecticut's Fair Employment Practices Act, and to preserve the anti-bias testing safe harbor the new discrimination amendment permits courts to consider. Businesses without a formal AI governance policy should prioritize developing one before the 2027 deadline.