Connecticut Enacts New AI Law Impacting Employers

On June 2, 2026, Connecticut Governor Ned Lamont signed into law the Connecticut Artificial Intelligence Responsibility and Transparency Act (the “CART Act”). Among its many provisions, the CART Act imposes new obligations on employers that use artificial intelligence and automated decision-making tools in employment decisions. This alert focuses on those requirements.

Key Definitions

The CART Act regulates the use of automated employment-related decision technology (“AEDT”). AEDT is defined broadly as any technology that processes personal data and uses computational methods to generate outputs, such as predictions, recommendations, classifications, rankings, or scores, that are used as a “substantial factor” in making or materially influencing an “employment decision.” There are several exclusions from this definition, but those exclusions may have limited practical effect. Excluded technologies include:

• Common workplace tools, such as word processors, spreadsheets, data storage systems, spam filters, robocall filters, and spellcheckers, but only to the extent they do not make or materially influence employment decisions;
• Systems or services used only incidentally to an employment decision; and
• Purely descriptive, diagnostic, or statistical information that is not relied upon to make or materially influence an employment decision.

The CART Act applies to a broad range of employment-related decisions, including hiring, promotion, discipline, termination, renewal of employment, selection for training or apprenticeship opportunities, and other decisions affecting an employee’s tenure, terms, privileges, or conditions of employment. The law excludes the following decisions from this definition:

• Decisions resulting in only nonmaterial changes to job duties, responsibilities, hours, or assignments; and
• Decisions relating to workplace health and safety, scheduling and planning, or productivity monitoring.

Finally, the statute broadly defines a substantial factor as a constraint, ranking, score, recommendation, classification, or other output that meaningfully alters the outcome of an employment decision involving an individual in Connecticut. This definition leaves significant room for interpretation.

New Compliance Requirements

The CART Act’s employment-related provisions take effect on a staggered basis.

There are two key provisions effective October 1, 2026:

• A provision making clear that employers cannot avoid liability under Connecticut’s anti-discrimination laws (to the extent they ever could) by attributing a challenged employment decision to an AEDT. However, the CART Act states that courts and the Connecticut Commission on Human Rights and Opportunities may consider evidence that an employer conducted “anti-bias testing or similar proactive efforts to avoid the discriminatory practice” when evaluating claims involving AEDT.
• A provision requiring employers—to the extent they are required by other laws to issue a mass-layoff notice—to disclose in that notice whether artificial intelligence informed the decision giving rise to the layoff.

The CART Act’s main AEDT provisions apply to AEDT deployed on or after October 1, 2027. Those provisions require the following:

• Employers that use AEDT to make or materially influence employment decisions must provide written notice to affected applicants and employees before a decision is made. The notice must:
  • Disclose that AEDT is being used;
  • Explain the purpose of the technology and the employment decision involved;
  • Identify the technology by trade name; and
  • Describe the categories and sources of personal data analyzed, as well as how that data will be evaluated.
• Employers must disclose when an applicant or employee is interacting directly with AEDT, unless that fact would already be obvious to a reasonable person.
• Developers (i.e., vendors) that market or provide AEDT for employment-related purposes must supply employers with the information needed to satisfy the law’s disclosure requirements, unless the parties agree by contract that the developer will assume those obligations.

Enforcement

The CART Act does not create a private right of action for alleged violations of its AEDT disclosure requirements. Enforcement authority rests exclusively with the Connecticut Attorney General.

The law also does not purport to regulate conduct outside of Connecticut. It applies only to employers doing business in Connecticut that deploy AEDT in the state, and covers only employment decisions affecting individuals in Connecticut.

What Employers Should Do Now

Although the CART Act generally takes effect on October 1, 2026, the statute’s principal AEDT notice and disclosure requirements generally will not apply until October 1, 2027. Employers should begin preparing to comply by:

• Identifying artificial intelligence-driven tools used in recruiting, hiring, promotion, discipline, termination, and other employment decisions;
• Assessing whether those tools may qualify as AEDT under the CART Act;
• Reviewing existing agreements with artificial intelligence, recruiting, and human resources technology vendors to determine what compliance assistance, disclosures, and indemnification provisions may be available;
• Evaluating whether bias testing or similar assessments are appropriate for artificial intelligence tools used in employment decisions; and
• Developing processes for complying with the CART Act’s AEDT-related disclosure requirements, including any applicable mass-layoff notices and future AEDT notices to applicants and employees.

If you have any questions related to the foregoing, please reach out to any member of the Employment practice below, or your primary Seward & Kissel attorney.