Connecticut became one of the first US states on October 1, 2026 to require employers filing mass-layoff notices to disclose whether artificial intelligence or other technological change was behind the cuts, as the disclosure provision of the state's AI Responsibility and Transparency Act, Public Act 26-15 took effect. The new obligation applies to any employer serving a federal WARN Act notice with the Connecticut Department of Labor and asks, in writing, whether the reduction in force is "related to the employer's use of artificial intelligence or another technological change," according to analysis by Epstein Becker Green.
- Statute
- Public Act 26-15 (CART Act), Section 1 (Connecticut Senate Bill 7, 2025 session)
- Effective date
- October 1, 2026
- Trigger
- Federal WARN Act notice to the state Labor Department
- Disclosure
- Whether the layoff is "related to the employer's use of artificial intelligence or another technological change"
- Form authority
- Connecticut Labor Commissioner
- WARN threshold
- 100+ full-time employees; mass layoff of 50+ at one site, or plant closing
- Enforcement
- Connecticut Attorney General, with a cure window running through December 31, 2027
What the new disclosure actually requires
Public Act 26-15, sometimes called the CART Act, was passed in the 2025 Connecticut legislative session as Senate Bill 7 and signed into law. Two of its provisions took effect on October 1, 2026: a ban on using AI as a defense to state Fair Employment Practices Act claims, and a written disclosure rule that piggybacks on the federal Worker Adjustment and Retraining Notification Act, according to Ford & Harrison.
Under the WARN-linked rule, any employer that serves a written notice with the Connecticut Department of Labor for a mass layoff or plant closing covered by federal WARN must now include whether the action was "related to the employer's use of artificial intelligence or another technological change." The exact form will be set by the Connecticut Labor Commissioner, but the statutory trigger is the federal WARN Act itself, according to Fisher Phillips.
Connecticut is one of the first US states to impose the requirement. "This makes Connecticut one of the first states in the country to require employers to identify any connection between workforce reductions and AI adoption," Fisher Phillips wrote in its May 2026 alert to clients.
Why Connecticut moved ahead of the federal WARN Act
Federal WARN has long required 60 days of advance written notice for covered mass layoffs and plant closings, but it does not ask employers to explain why the cuts are happening or whether technology played a role. Connecticut is layering the AI question on top of the existing federal form rather than creating a parallel regime, which keeps the trigger simple: if WARN applies, the AI disclosure does too, according to Nixon Peabody.
The state is also part of a broader 2026 wave of state-level AI employment laws. Akin Gump's tracker of the patchwork lists Connecticut alongside California, Colorado, Illinois, and a handful of others that have moved first on workplace AI rules, with disclosure and notice obligations landing on different effective dates, according to Akin Gump.
For employers operating across multiple states, the practical effect is that Connecticut WARN notices now carry a yes-or-no question that federal notices do not, and the answer will be visible to state labor officials rather than only to internal HR records.
Who is affected when the next WARN notice goes out
The rule attaches to the same threshold as federal WARN. In Connecticut, that means employers with 100 or more full-time workers who are planning a mass layoff affecting at least 50 employees at a single site of employment, or a plant closing, must add the AI disclosure to the notice they file with the state Department of Labor. Companies below those thresholds are not required to file a WARN notice and are not caught by the disclosure requirement, even if they are making AI-driven reductions in smaller groups.
For software, data, and operations teams inside those employers, the disclosure forces an internal question that previously did not have to be answered in writing: did the layoff decision turn, in whole or in part, on an AI tool used to score applicants, automate scheduling, or model workforce needs. The Connecticut rule asks employers to make that determination before the notice is filed, rather than letting companies keep the answer internal, according to Cohen and Wolf.
Affected workers in Connecticut will not see the AI disclosure directly on their individual WARN notice unless their employer chooses to surface it. The state Department of Labor is the recipient, and the new form fields will be part of the file the agency holds on each covered action.
What remains unanswered under the new rule
The October 1, 2026 provision does not yet spell out what happens if an employer answers the AI question incorrectly or omits it. The state Attorney General has enforcement authority over the broader CART Act, with a cure period running from October 1, 2026 through December 31, 2027, but the WARN disclosure itself does not carry a separate listed penalty in the legal alerts reviewed for this article, according to Ford & Harrison.
A second, separate set of CART Act rules requiring AI-specific notice for hiring, promotion, and termination decisions does not take effect until October 1, 2027. That means the first months of the WARN disclosure will play out without the broader employment-decision notice framework alongside it, and the first WARN filings under the new rule will be the earliest test of how Connecticut labor officials handle the AI field in practice.
For recruiters, candidates, and HR teams, the immediate consequence is procedural rather than substantive: the next Connecticut WARN notice now asks a new question, and the answer will be on file with the state.
Primary source
Check the original source
Connecticut General Assembly — Senate Bill 7 (2025) / Public Act 26-15 is the source to consult for the underlying data, statement, ruling or live context.