Connecticut’s 2026 legislative session imposed significant workplace obligations on employers and others through the enactment of Public Act No. 26-12, An Act Concerning Workforce Development and Working Conditions in the State. The Act expands pay transparency, disability accommodations, wage enforcement, and worker retention obligations, with phased effective dates beginning in October 2026 and continuing into 2027. The Act affects public- and private-sector employers and imposes significant obligations on both.
Key Takeaways
- Beginning October 1, 2026, Connecticut employers must expand pay and benefits disclosures in job postings.
- Within 120 days of October 1, 2026 (by January 29, 2027), employers must provide notices to employees regarding the right to request disability-related reasonable accommodations.
- The Act imposes joint and several liability for certain unpaid wages on covered construction projects beginning January 1, 2027.
- Effective October 1, 2026, the Act adds new prevailing-wage recordkeeping requirements and clarifies the method by which prevailing wage rates are calculated.
- Beginning July 1, 2027, successor employers and contractors will be required to retain workers provided through certain covered service contracts for a minimum of 90 days.
Enhanced Workers’ Compensation Benefits for Health Care Workers and Educators Assaulted at Work
Effective October 1, 2026
The Act increases workers’ compensation benefits for health care workers and educators who are injured due to a physical assault resulting from negligent conduct while working. If the assault renders the worker totally or partially unable to work, the worker is entitled to replacement wage benefits equal to 100% of the worker’s average weekly wage, with no caps. Currently, wage replacement benefits are about 75% of the average weekly wage, with caps.
The worker must also be compensated for reasonable medical expenses that are related to the assault, as well as lost wages for missed work from attending a court appearance connected to the incident. The worker must continue to receive full pay while they are absent from work due to the injury or court appearance. The employer may, however, deduct any workers’ compensation amounts from wage payments. The absences cannot be counted against the worker’s sick leave, vacation, or personal time.
These benefits apply to:
- Teachers
- Members of education boards
- Student teachers
- Health care workers who provide direct patient care
- Health care workers who have direct contact with the patient or the patient’s family.
Mandatory Wage and Benefit Disclosure in Job Postings
Effective October 1, 2026
The Act expands existing disclosure requirements on internal and external job postings to include pay ranges and benefits. Employers must disclose the wage or wage range for a position and provide a general description of the benefits offered, including health insurance, retirement, fringe benefits, paid leave, and any other compensation. Employers may not retaliate against an applicant (for example, by refusing to interview or hire the applicant) if the applicant exercises the right to request such information.
These requirements apply only to positions whose primary duties will be performed in Connecticut or where the employee performing the duties will report to a supervisor or worksite located within the state.
Prohibition on Promissory Notes Expands to All Employers
Effective October 1, 2026
The ban on promissory notes as a condition of employment now applies to employers of any size, eliminating the previous exemption for employers with fewer than 26 employees. These notes require an employee to pay the employer if the employee leaves before a specified period. Any promissory note executed on or after October 1, 2026, will be void.
Minimum Wage at Cannabis Establishments
Effective October 1, 2026
The Act prohibits cannabis establishments, dispensaries, or producers from counting tips or gratuities toward minimum wage. Any employer that agrees to pay less than minimum wage will be in violation of the law.
New Tenured Teacher Termination Procedures
Effective July 1, 2026
The Act now requires that the standard of review for the grounds on which a tenured teacher may be terminated will be the same standard applied in other disciplinary actions under the terms of such teacher’s collective bargaining agreement. Typically, this would be a “just cause” standard. It establishes that impartial hearing officers must hear dismissal cases, replacing board hearings. The hearing officer’s decision is now binding, subject to judicial review. Boards of education, like teachers, may seek judicial review.
Retention of Service Contract Workers
Effective July 1, 2027
This new provision imposes advance notice and worker retention requirements on certain entities at covered locations, where: (1) a service contract is terminated or not renewed; (2) an owner/employer awards a service contract to an outside entity, which would displace the owner/employer’s own employees; or (3) an owner/employer sells or transfers a property in which service workers are employed. Affected employees must be given at least 15 days’ notice before any of the foregoing events.
Upon one of these triggering events, a successor or entity awarding the contract is obligated to retain such service workers for at least 90 days. At the end of that period, the successor must provide a written offer of continued employment to any worker whose performance is satisfactory. However, the successor may decline to retain workers whose prior performance or attendance would lead a reasonably prudent employer to terminate them. The successor may also reduce headcount if fewer workers are needed, provided that terminations are made by seniority within job classifications.
Successor contractors and employers may be held liable if an employee is terminated in violation of these requirements. An affected employee may enforce these rights through a lawsuit or an administrative complaint and need not exhaust administrative remedies before filing suit.
Disability Accommodation Disclosures
Effective October 1, 2026
The new statute requires employers to notify employees of their rights under the Americans with Disabilities Act (ADA). An employer must provide all new employees with written notice of their right to request a reasonable workplace accommodation when they begin their employment. Current employees must be notified within 120 days of October 1, 2026, and new employees upon hire. Thereafter, if an employee informs the employer of a disability, the employer must provide notice of the employee’s rights to reasonable accommodation within 10 days. An employer may satisfy the notice requirement by displaying a poster created by the Labor Commissioner in a conspicuous location in the workplace.
Increase in Lactation Break Periods
Effective October 1, 2026
The Act expands on the circumstances under which employees are free to breastfeed or express breast milk at work. Employers must now provide “reasonable break times” to express breast milk in addition to regularly scheduled break periods already required under existing law. Employers must continue to ensure access to space where the employee can express breast milk in private, provided that it is shielded from the public and free from intrusion, situated near a refrigerator, and has access to an outlet.
Enhanced Pay Code Transparency
Effective October 1, 2026
The Act expands wage-transparency obligations to employers with 100 or more employees. Covered employers must create a guide of at least 10 pay codes for overtime and commonly used pay differentials, such as shift differentials, on‑call pay, hazard pay, call‑back pay, holiday or weekend pay, and geographic pay differentials. The employer must post these guides on their website in English, Spanish, and any other language commonly spoken by employees. The employer must also provide new hires with the guide’s web address (if the employer maintains such a website) and include that address on each record of hours and wages provided to an employee. Compliance with this requirement can be satisfied by using third-party payroll services that supply a pay code guide.
New Prevailing Wage Recordkeeping Requirements
Effective October 1, 2026
The Act now requires employers on Connecticut public works projects to prepare daily records for each person working on a job site as a mechanic, laborer, or worker. Each daily record must include:
- The project name and location
- The current date
- The employee’s printed name and signature, and (if applicable) the employee’s trade license number
- The employee’s arrival and departure time at the job site.
The employer must keep these records and submit them weekly to the contracting agency or Department of Economic and Community Development. Failing to file records will result in a Class C misdemeanor. The statute expressly clarifies that these records are public records under the Freedom of Information Act.
The Act also updates how prevailing wages are set. When determining the prevailing wage and required benefit payments for a public works contract in a particular town, the Labor Commissioner must now consider the journeyman rate, in addition to other factors.
Contractor Liability for Wage Theft
Effective January 1, 2027
General contractors are now jointly and severally liable for the subcontractor’s failure to pay its employees’ wages. See Harris Beach Murtha’s previous alert titled Conn. Enacts Law Expanding Upstream Liability for Unpaid Construction Wagesfor more information.
Harris Beach Murtha’s Labor and Employment Practice Group will continue to monitor these issues and report on new developments. If you have questions or need assistance with this or other labor matters, please reach out to attorney Salvatore G. Gangemi at (203) 653-5436 and sgangemi@harrisbeachmurtha.com, or the Harris Beach Murtha attorney with whom you most frequently work.
This alert is not a substitute for advice of counsel on specific legal issues.
Harris Beach Murtha’s lawyers and consultants practice from offices throughout Connecticut in Bantam, Hartford, New Haven and Stamford; New York State in Albany, Binghamton, Buffalo, Ithaca, New York City, Niagara Falls, Rochester, Saratoga Springs, Syracuse, Long Island and White Plains; as well as in Boston, Massachusetts, and Newark, New Jersey.