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Public Act No. 26-15: An Act Concerning Online Safety

Connecticut Online Safety Act

PassedBoth

Jurisdiction

Connecticut, United States

Status

Passed

Live from

1 October 2026

Compliance deadline

1 October 2027

What this regulation is

Connecticut Public Act No. 26-15 regulates several aspects of artificial intelligence and online safety. Notably, Sections 7 through 14 target 'automated employment-related decision technology'. From October 1, 2027, employers must disclose to applicants and employees if they are interacting with such technology. Furthermore, before an employment-related decision is made using its outputs as a substantial factor, employers must provide a written notice outlining the data processed, its sources, and the system's purpose. The act explicitly states that using an automated tool does not constitute a defense against discrimination complaints under existing state civil rights laws, though proactive anti-bias testing may be considered as evidence by courts or commissions.

Regulator or body

Office of the Attorney General

Audience impact

What different teams need to know

HR and recruitment teams

Beginning October 1, 2027, HR departments operating in Connecticut must implement clear processes to provide plain-language interactive disclosures and detailed written notices to candidates and employees before making automated hiring, promotion, discipline, or termination decisions. Additionally, employers are legally restricted from using automated system metrics as a shield against employment discrimination claims, magnifying the legal risk of unvetted vendor tools.

HR technology vendors

HR technology vendors selling automated recruitment, assessment, or performance management software used in Connecticut must provide all necessary system and data information to employers to facilitate their compliance duties from October 1, 2027. Vendors can contractually assume the employer's disclosure and notice duties. Crucially, the quality and recency of anti-bias testing conducted by vendors on these tools will serve as a key evidentiary factor for their clients in downstream discrimination disputes.

Status intelligence

Current status and key dates

Regulatory status

Enacted (Effective dates vary, automated employment provisions effective October 1, 2026)

Date timeline

Passed
Not specified

Live from
1 October 2026

Enforcement / compliance
1 October 2027

Mandatory audit scope

Bias auditing and protected characteristics

Bias audit summary

The source mentions anti-bias testing as evidence that may be considered by a commission or court to evaluate proactive efforts to avoid discriminatory practices, but does not appear to create a freestanding external, independent, periodic, or pre-deployment bias audit requirement.

Protected characteristics summary

The law explicitly reinforces employment discrimination protections for a wide array of protected classes, stipulating that automated technology cannot defend against claims involving race, color, religious creed, age, sex, gender identity/expression, sexual orientation, civil union status, marital status, national origin, ancestry, genetic information, veteran status, domestic violence/sexual assault victim status, and various forms of intellectual, learning, or physical disability.

Duties and legal nuance

Obligations and requirement levels

Binding duties are shown as compact cards. Evidence and notes are collapsed by default.

Transparency Disclosure

BindingApplies to: DeployerExpress

Trigger and timing

Trigger: Deploying automated employment-related decision technologies intended to interact with an employee or applicant in the state

Timing: On or after October 1, 2027, during interaction

Source: Sec. 9

Evidence

a deployer who, on or after October 1, 2027, deploys one or more automated employment-related decision technologies that are intended to interact with an employee or applicant for employment in the state shall ensure that it is disclosed to each such employee or applicant who interacts with such technology or technologies that such employee or applicant is interacting with such technology or technologies. Such disclosure shall be made in plain language.

Notes

Disclosure is waived if a reasonable person would deem the automated interaction completely obvious.

Candidate Notice

BindingApplies to: DeployerExpress

Trigger and timing

Trigger: Deploying automated employment-related decision technology to generate output used as a substantial factor in making an employment-related decision

Timing: Before the employment-related decision is made

Source: Sec. 10

Evidence

a deployer who, on or after October 1, 2027, deploys an automated employment-related decision technology to generate any output for the purpose of making, or as a substantial factor in making, an employment-related decision concerning an employee or applicant for employment in the state shall, before such employment-related decision is made, provide to such employee or applicant a written notice disclosing...

Notes

The written notice must specify the trade name, purpose, data categories analyzed, data sources, and deployer contact info.

Documentation

BindingApplies to: ProviderExpress

Trigger and timing

Trigger: When an automated employment-related decision technology is deployed or marketed for material use in employment decisions within the state

Timing: On or after October 1, 2027, upon deployment

Source: Sec. 8(a)

Evidence

the developer of an automated employment-related decision technology that is deployed in the state on or after October 1, 2027, shall provide to the deployer of such automated employment-related decision technology all information that such deployer requires to perform such deployer's duties under sections 9 and 10 of this act.

Notes

Developers can contractually assume the deployer's notice and disclosure duties.

Bias Audit

MentionedApplies to: DeployerExpress

Trigger and timing

Trigger: Defending against an employment discrimination complaint involving automated systems

Timing: During judicial or administrative proceedings

Source: Sec. 13(b)(1) & Sec. 14

Evidence

The use of an automated employment-related decision technology... shall not be a defense against a complaint alleging a discriminatory practice... The commission or court may consider evidence of anti-bias testing or similar proactive efforts to avoid the discriminatory practice, including, but not limited to, the quality, efficacy, recency and scope of such testing or efforts, the results of such testing or efforts and the response thereto.

Notes

Anti-bias testing is an evidentiary mitigating factor, not a standalone mandatory compliance audit.

Actor split

Who the record says is responsible

Primary liability role: Both

Employer / employment agency duties

Transparency Disclosure · BindingCandidate Notice · BindingDocumentation · BindingBias Audit · Mentioned

Vendor support context

Hiring and employment use cases

Affected use cases

ScreeningExpressly coveredExpress

'Employment-related decision' (A) means any decision, made based on any individual's personal data, to hire, promote, discipline or discharge such individual, to renew such individual's employment, to select such individual for any training or apprenticeship

Source: Sec. 7(5)

Hiring and candidate selection processes explicitly activate compliance duties.

RankingExpressly coveredExpress

uses computation to generate any output, including, but not limited to, any prediction, recommendation, classification, ranking, score or other information, that is a substantial factor used to make or materially influence an employment-related decision

Source: Sec. 7(1)

Systems that rank or score applicants are specifically targeted by the definition of the technology.

AssessmentExpressly coveredExpress

uses computation to generate any output... that is a substantial factor used to make or materially influence an employment-related decision

Source: Sec. 7(1)

Algorithmic skills and cognitive assessments are included.

PromotionExpressly coveredExpress

to hire, promote, discipline or discharge such individual

Source: Sec. 7(5)

Internal vertical mobility decisions are protected.

TerminationExpressly coveredExpress

to hire, promote, discipline or discharge such individual

Source: Sec. 7(5)

Algorithmic terminations or automated disciplinary actions trigger strict compliance thresholds.

General Employment AdmExpressly coveredExpress

meaningfully alters the outcome of an employment-related decision concerning an individual in the state

Source: Sec. 7(1) & (5)

Excludes minor modifications to shifts, schedules, job tasks, or physical workplace health and safety protocols.

Primary source

Source

Regulator or body

Office of the Attorney General

Source documents

Substitute Senate Bill No. 5 / Public Act No. 26-15: An Act Concerning Online Safety

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