What Does Connecticut’s Public Act 26-15 Require Employers to Disclose About AI-Caused Layoffs?

Starting October 1, 2026, any Connecticut employer filing a WARN Act layoff notice must also tell the state Department of Labor whether artificial intelligence caused the reduction in force. That is the first operative deadline under Connecticut’s new AI employment law, Public Act 26-15 (enacted as Substitute Senate Bill 5), and it lands in two days for any company already planning a fall layoff.

Two more deadlines follow in 2027. Frontier AI developers must stand up whistleblower reporting channels by January 1, and a full automated-decision-tool notice regime for employers arrives October 1, a full year after the WARN rule takes hold. This guide covers what changes now, what to document before the October 1 deadline, and what comes next so nobody gets caught out twice.

This is a compliance and operations guide, not legal advice. Connecticut’s Labor Department has not published detailed guidance on the disclosure form, and the specifics below come from the enacted statute and from employment-law commentary attributed by name throughout. Confirm any policy change with employment counsel before you act.

What Is Connecticut Public Act 26-15 and Who Has to Comply?

Public Act 26-15, enacted as Substitute Senate Bill 5, is Connecticut’s new artificial intelligence law covering employment, frontier AI safety and several unrelated consumer-protection provisions. Its employment sections apply to any employer already required to file a federal WARN Act notice, plus any employer or vendor that deploys automated tools in hiring, discipline or termination decisions.

The law does not create a brand-new layoff-notice regime. It attaches a disclosure duty to the WARN filing employers already make, then layers on separate obligations for AI developers and for employers using automated decision technology on a longer runway. Read the full text of Public Act 26-15 alongside the state’s existing filing process on the Connecticut Department of Labor’s WARN page.

Employers with no Connecticut-specific employment counsel are the ones most likely to miss this. Nothing in the federal WARN Act mentions artificial intelligence, so a national HR team following only the federal template will file a technically incomplete notice starting this week.

What Must a WARN Notice Disclose When AI Causes a Layoff in Connecticut?

Under Section 26 of Public Act 26-15, an employer serving a federal WARN Act notice on the Connecticut Department of Labor must also disclose whether the layoffs “are related to the employer’s use of artificial intelligence or another technological change,” in a form the Labor Commissioner prescribes. The requirement is a disclosure duty, not a ban or a delay trigger.

The statute’s own language is short, and Connecticut has not yet published the specific form referenced in Section 26. Until it does, the safest reading, per Ogletree Deakins’ analysis of the law, is to treat the disclosure as a yes-or-no attestation attached to the existing notice rather than a new standalone filing.

That single answer still has teeth. It creates a discoverable, state-held record of whether an employer characterized a layoff as AI-driven, which matters if a former employee later challenges it as pretextual or discriminatory.

How Do Employers Decide Whether a Layoff Is “AI-Caused”?

Public Act 26-15 does not define how an employer determines that a layoff relates to AI or specify a threshold of AI involvement that triggers the disclosure. That gap is an interpretation problem for employers right now, not a settled legal test, and Connecticut’s Labor Department has not issued guidance filling it as of this writing.

In practice, most RIFs involve AI at some level, whether that is a forecasting model flagging a shrinking product line, an automation rollout that eliminates a role’s tasks, or a generative-AI tool that absorbed work previously done by a team. The statute does not distinguish “AI replaced this job” from “AI made this team more efficient, so we need fewer people.”

Employment counsel quoted in Fisher Phillips’ employer to-do list recommends employers document their reasoning for whichever answer they give, since the honesty and consistency of that characterization, not just the answer itself, is what a regulator or plaintiff’s attorney will test later.

What Documentation Should HR and L&D Teams Build Before October 1, 2026?

Before the deadline, HR and compliance teams need a written record connecting each eliminated role to the business reason behind it, including any automated tool, model or analytics output that fed into the decision. That record should exist in the RIF planning file itself, not be reconstructed afterward to justify the WARN filing.

Three things belong in that file: a list of every system, human-authored or AI-assisted, that fed the layoff decision; a plain-language note on how much weight each input carried relative to ordinary business judgment; and the name of the person who made the final call and signed off on the WARN characterization.

This is the same discipline that audit evidence for compliance training programs already requires for certification records. If your organization runs training data management practices that track enrollment, attendance and completion, extending that system of record to RIF decision-attribution is a smaller lift than starting from nothing.

What Are the Three Key Compliance Dates Under Public Act 26-15?

Public Act 26-15’s employment provisions roll out on three dates over roughly twelve months: October 1, 2026 for WARN disclosure, January 1, 2027 for frontier-developer whistleblower channels, and October 1, 2027 for automated decision tool notices. Each date targets a different audience.

Notice the gap between the first and third dates. Connecticut gave employers a year of runway between the WARN disclosure duty and the harder automated-decision-tool regime, unusual generosity by state AI-law standards, and worth using.

How Does This Differ From the Federal WARN Act Baseline?

The federal WARN Act requires 60 days’ advance written notice of a mass layoff or plant closing from employers with 100 or more employees, filed with the state and affected workers, but it says nothing about artificial intelligence. Connecticut’s Public Act 26-15 does not change the 60-day timeline or the employee-count threshold; it only adds a disclosure question onto the notice that already has to go out.

That makes the compliance burden additive, not a parallel system. An employer with a working federal WARN process, per the federal WARN Act’s notice requirements, mainly needs one more field in that process and someone who can defend the answer given.

The risk is treating this as a check-box formality. Because the AI-relatedness answer becomes a state record, an inconsistent answer is a bigger liability than a late filing would be.

What Happens on January 1, 2027 Under the Whistleblower Provision?

From January 1, 2027, “large frontier developers,” a narrow category of companies building the most capable AI models, must establish an internal process letting employees anonymously report safety concerns involving catastrophic risk, without fear of discharge or discipline for doing so. This provision targets AI labs, not the typical Connecticut employer using AI tools in HR.

Section 2 bars a frontier developer from adopting any “rule, regulation, policy or contract” that lets it discharge, discipline or penalize an employee for reporting catastrophic-risk concerns, and requires the anonymous reporting channel by January 1, 2027. Enforcement runs through the Connecticut Attorney General, with civil penalties up to $1,000 per violation.

For most readers, this section is background rather than a direct obligation. It matters because any AI vendor you buy tools from may itself be a covered frontier developer, and its compliance posture is a fair question for your next procurement review.

What Automated Decision Tool Notice Duties Start on October 1, 2027?

Beginning October 1, 2027, an employer or vendor deploying an automated employment-related decision technology, defined as any technology that processes personal data and uses computation to produce output that is a substantial factor in an employment decision, must disclose that fact to the employee or applicant interacting with it. A separate, more detailed pre-decision notice is also required.

That pre-decision notice must cover the tool’s purpose, its trade name, the categories of personal data it analyzes and how that data gets assessed, the data’s sources, and contact information for the deployer. No notice is required where it would already be obvious to a reasonable person that they are interacting with automated technology.

The law carves out ordinary business software, including word processors, spreadsheets, spell-checkers, navigation tools, antivirus software and spam filters, plus nonmaterial job changes, scheduling and productivity monitoring. A completion-tracking dashboard is unlikely to qualify on its own; a scoring model that ranks candidates or flags employees for discipline sits squarely inside the definition.

How Does Connecticut’s Law Compare With Colorado and California’s AI Employment Rules?

Connecticut is one of three states moving on AI employment rules in the same window: Colorado’s amended AI Act takes effect January 1, 2027 with Attorney General rules still being finalized, and California’s SB 947 and AB 1883 remain pending as of this writing. Each state picked a different regulatory lever.

A multi-state employer ends up building one documentation habit and applying it everywhere. Connecticut’s WARN disclosure, Colorado’s AI Act rulemaking and California’s SB 947 bill text converge on the same ask: show your work on how an automated system influenced a decision about a real person’s job.

What Penalties Apply if an Employer Misses the Disclosure Requirement?

Connecticut treats a violation of the automated decision tool notice provisions as an unfair or deceptive trade practice, enforced exclusively by the state Attorney General with no private right of action, and it allows a 60-day cure period for violations that occur before December 31, 2027. Separate whistleblower violations by frontier developers carry civil penalties of up to $1,000 per violation.

The statute is explicit on one more point: using an automated decision tool is not, by itself, a defense against a discrimination complaint. Evidence of bias testing may count as a mitigating factor, but it does not excuse the underlying outcome.

Connecticut’s choice to route enforcement solely through the Attorney General, with no private right of action for notice violations, is narrower than California’s proposed approach, which would let affected workers sue directly. That difference matters if your organization also operates in California.

What Should HR, L&D and Compliance Teams Build Right Now?

The practical response to Public Act 26-15 is four concrete steps, starting with an inventory of every system touching a hiring, discipline or termination decision and ending with a calendar that already has the 2027 deadlines on it. None of this requires new software if your existing training and compliance systems already track records well.

Step 1: Inventory every system that touches a hiring, discipline or termination decision

List every tool, marketed as “AI” or not, that scores, ranks, flags or forecasts anything tied to a person’s job, including vendor analytics inside your LMS or HRIS.

Step 2: Assign a named owner for AI-attribution documentation

Someone specific, not “HR” as a department, owns the RIF decision-attribution record and the WARN disclosure answer. Naming that owner turns a policy into a habit.

Step 3: Rewrite your WARN notice template now

Add the AI-relatedness field to your internal WARN checklist and draft the supporting rationale before a layoff is imminent, while there is time to get it right.

Step 4: Calendar the 2027 deadlines and start vendor conversations early

October 1, 2027 feels distant, but the pre-decision notice content, trade names, data categories, data sources, needs vendor cooperation that takes months to line up.

Pairing this work with AI agent governance training for the managers who will actually complete these disclosures closes the gap between having a policy and having people who can execute it correctly. A documented LMS governance framework that already assigns clear ownership over similar audit questions is the fastest place to bolt this new responsibility onto, rather than standing up a parallel process.

Is This Confirmed by Connecticut’s Own Statute or Just Law-Firm Commentary?

The operative dates, section numbers and quoted statutory language in this guide come directly from the enacted text of Public Act 26-15 published by the Connecticut General Assembly. Interpretive points, such as how to read the undefined “AI-related” standard or what a practical to-do list looks like, are attributed by name to Ogletree Deakins and Fisher Phillips, both employment-law firms publishing client alerts rather than government sources.

That distinction matters because Connecticut’s Labor Department has not yet released the specific disclosure form Section 26 references, so any description of that form is a prediction, not a confirmed fact. Treat this guide, and any coverage published before the form appears, as a reading of the statute rather than a substitute for it.

Conclusion

Connecticut’s WARN disclosure requirement takes effect in days, not months, and it is the kind of deadline a national HR team following only a federal template will miss without ever realizing it. Pull your current WARN process this week and confirm someone owns the AI-relatedness answer before the next Connecticut layoff notice goes out.

Then use the runway Connecticut gave you. A full year sits between the October 2026 disclosure duty and the October 2027 automated-decision-tool notice regime, and that time is best spent building the decision-attribution habit once so it covers both deadlines, plus whatever Colorado and California finalize in the meantime.

If your organization operates in more than one state, read this guide alongside your Colorado and California compliance tracking rather than as a Connecticut-only checklist. The documentation habit is the same everywhere; only the filing deadlines and enforcement paths differ.