Regulatory  ·  2026-05-30

Connecticut Enacts AI Responsibility and Transparency Act (SB 5) — Requires Automated Employment Decision Disclosures and AI-Linked WARN Notices

RegulatoryHigh impactUnited States
Governor Ned Lamont signed Connecticut Senate Bill 5, the Connecticut Artificial Intelligence Responsibility and Transparency Act, into law. The 39-section statute creates obligations for automated employment-related decision technology (AEDTs), companion chatbots, generative AI provenance, and workforce development, with staggered effective dates beginning October 1, 2026 through January 2028. Crucially, as of October 1, 2026, employers filing WARN Act notices must disclose whether layoffs are related to AI or technological change, making Connecticut one of the first US states to require AI-linked layoff disclosures.
Connecticut's law signals accelerating US state-level AI employment regulation: it explicitly bars employers from using 'the algorithm made the decision' as a defence against discrimination claims, and requires pre-decision written notices when AI plays a 'substantial factor' in hiring, promotion, or termination — obligations that apply to widely-used HR tools including third-party resume screeners and scheduling algorithms. Organisations with Connecticut employees or supervisors need to audit automated HR tools before October 1, 2026.
Inventory all automated employment decision tools across recruitment, performance management, and workforce-planning workflows; determine which qualify as AEDTs under SB 5; begin vendor contract negotiations to allocate developer vs. deployer disclosure duties; and update WARN Act template notices to include AI-attribution disclosures ahead of October 1, 2026.
Sources
Future of Privacy Forum — SB 5 in FiveFisher Phillips LLP — Connecticut Employers PrepareForbes — Connecticut AI Law Analysis
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