Connecticut’s Public Act No. 26-12 is a broad omnibus employment measure that expands employer compliance obligations across hiring, wage practices, accommodations, construction liability and worker-retention rules. The law takes effect in stages, with major implementation dates on October 1, 2026, January 1, 2027, and July 1, 2027.
Additionally, Connecticut’s Public Act No. 26-73 expands employer compliance obligations related to electronic monitoring of employees effective October 1, 2026.
In this alert, we highlight key changes and action steps employers should take to comply.
Highlights:
- Beginning October 1, 2026, Connecticut employers must expand pay and benefits disclosures in job postings and provide accommodation-related notices to employees.
- The Act strengthens wage-enforcement tools, adds new prevailing-wage recordkeeping requirements, and creates joint-and-several liability for certain unpaid wages on covered construction projects beginning January 1, 2027.
- Successor employers assuming covered service contracts will face worker-retention obligations beginning July 1, 2027.
- Employers should evaluate job posting templates, payroll communications, accommodation notices, electronic monitoring notices and construction-related compliance policies and practices and modify as necessary.
Wage, Compensation, and Pay Transparency
- Pay Transparency: Job Postings, Wage Ranges, and Benefits Disclosures
What Changed: Connecticut joins at least 14 states requiring employers to include pay ranges and benefits in both internal and external job postings, expanding its existing disclosure requirements. Effective October 1, 2026, employers must include wages or a “good-faith wage range” and a general description of benefits in internal and public job advertisements. If there is no job advertisement, employers must provide these disclosures upon request or before any compensation discussion or offer – rather than the current standard of by or at the time an offer is made. The Act clarifies that it applies to Connecticut-based positions and positions performed out of state if the employee reports to Connecticut-based supervisors, offices or worksites. Additionally, the Act protects from retaliation anyone who exercises pay-transparency rights.
Action Steps:
- Audit all Connecticut job postings – external and internal – to confirm they include wage or wage range and a general benefits description.
- Adopt a documented process for setting good-faith wage ranges before positions are posted or compensation is discussed.
- Train recruiters, hiring managers and third-party staffing partners not to discuss compensation until required disclosures have been provided.
- Update applicable anti-retaliation policies to expressly protect applicants and employees who exercise pay-transparency rights.
- Expanded Restrictions on Employment Promissory Notes or “Stay or Pay” Agreements
What changed: Effective October 1, the Act extends the ban on employer promissory notes or “stay or pay” agreements to all employers – regardless of size. Current law restricts employers with 26 or more employees. Now, all Connecticut employees are prohibited from requiring employees or prospective employees, as a condition of employment, to sign employment promissory notes requiring repayment if the employee leaves before a stated period. Such notes are void as against public policy, though the Act preserves certain exceptions, including repayment of advances, payment for employer property, sabbatical terms for educational personnel and collectively bargained programs.
Action Steps:
- Inventory offer letters, training repayment agreements, tuition or certification reimbursement forms and onboarding packets for repayment obligations.
- Remove or revise provisions that condition employment on repayment for training or similar costs if the employee separates early.
- Confirm any retained repayment obligations fit within a statutory exception and are not framed as a prohibited employment promissory note.
- Paycheck Transparency For Employers with at Least 100 Employees
What Changed: Effective October 1, employers with at least 100 employees must create a plain-language guide explaining overtime pay codes and the employer’s most common pay differentials, such as shift differentials, on-call pay, hazard pay, holiday pay and weekend pay. The guide must include required contact information for disputes and must be made available in English, Spanish and other common employee languages or through an equivalent written process.
Action Steps:
- Determine which pay codes and differentials are most commonly used.
- Prepare a plain-language pay-code guide covering overtime and at least the required commonly used differentials.
- Translate the guide into required employee languages and decide whether it will be posted internally or distributed in writing upon hire.
- Assign payroll or HR responsibility for updating the guide whenever new covered pay codes are added.
- Minimum Wage at Cannabis Establishments
What changed: Effective October 1, gratuities are excluded from minimum fair wage at cannabis establishments, dispensary facilities and producers. Now, cannabis employers must pay employees at least Connecticut’s minimum wage and cannot count tips toward that amount.
Action Steps:
- Review payroll practices to ensure cannabis workers receive at least the full minimum fair wage – without tip credit.
- Train payroll and HR on the new requirements.
- Prevailing Wage Recordkeeping and Rate Calculations
What Changed: Effective October 1, employers on Connecticut public works projects are subject to prevailing wage requirements. As a result, such employers must maintain daily attendance records for each mechanic, laborer or worker at a work site, including project information, the current date, each worker’s printed name or signature, applicable trade license number, and arrival and departure times. Employers must submit these records weekly to the contracting agency, the Department of Economic and Community Development, or the covered-project developer, as applicable.
Daily records are considered public records subject to the Freedom of Information Act (FOIA). As a result, failure to file the applicable records may result in criminal penalties (including imprisonment) and/or fines.
The Act also updates how prevailing wage rates are calculated on public works projects. The Labor Commissioner must now use the journeyman rate to calculate the portion attributable to benefit payments and contributions such as health insurance and retirement benefits.
Action Steps:
- Create a daily sign-in/sign-out template that captures all required information, including trade license numbers, where applicable.
- Assign responsibility at each covered job site for collecting records daily and submitting them weekly.
- Align subcontractor agreements with the new recordkeeping requirement and require lower-tier compliance certifications.
- Train project managers on new requirements, including that daily records will be public records and must be accurate, complete and consistently retained.
6. Contractor Liability for Unpaid Wages
What Changed: Starting January 1, 2027, general contractors on Connecticut construction, renovation and rehabilitation projects can be held responsible for certain unpaid wages owed by their subcontractors. Before an employee files suit against the general contractor, the employee must give 30 days’ notice of the alleged wage violation, unless the employee already raised the same or a related issue involving that subcontractor. General contractors may include language in subcontracts allowing unpaid wages to be paid from retainage; that language will not limit an employee’s right to sue or reduce the general contractor’s statutory liability.
Action Steps:
- Update subcontract agreements to require timely wage payment, certified payroll or payroll records, indemnification, cooperation with investigations and retainage rights.
- Build a process to respond quickly to employee wage notices, including a 30-day investigation and resolution timeline.
- Require subcontractors to promptly notify the general contractor of wage complaints, payroll disputes or Department of Labor inquiries.
Accommodations
- Employer Notice of Reasonable Disability-Related Accommodations
What Changed: Effective October 1, 2026, all Connecticut employers must notify employees of their right to request reasonable accommodations for disabilities. This creates a practical need to confirm that accommodation policies, posters, onboarding materials and HR response procedures are current and accessible.
Action Steps:
- Review equal employment opportunity, disability-accommodation and interactive-process policies for consistency with Connecticut requirements.
- Update onboarding packets, employee handbooks, intranet pages and workplace posting locations to include the required notice.
- Document requests, interactive processes and accommodation decisions.
- Expanded Lactation Break Requirements
What Changed: October 1, 2026, brings enhanced protections for breastfeeding employees. All Connecticut employers must now provide reasonable break times for employees to express breast milk or breastfeed on site at the workplace, beyond regularly scheduled breaks. This marks a shift from prior law, which limited lactation activities to meal or break periods. Existing requirements remain in place, including that employers provide a private space near the work area equipped with refrigeration and an electrical outlet.
Action Steps:
- Update lactation break policies to state that reasonable break time is available in addition to regular breaks.
- Confirm designated lactation spaces meet legal requirements and are available when needed.
- Review timekeeping codes and payroll practices to ensure consistency in how lactation breaks are handled.
Health Care
- Hospital Nurse Staffing Compliance Reporting
What Changed: Effective October 1, Connecticut hospitals must maintain detailed nurse staffing plans, regularly report compliance data to the Department of Public Health and demonstrate that they meet at least 80 percent of required staffing assignments. The Act strengthens oversight by requiring supporting data, authorizing audits and providing for corrective action plans and civil penalties for noncompliance.
Action Steps:
- Audit current nurse staffing plans to confirm they are complete, current and tied to actual unit-level assignments.
- Create a tracking process to measure whether the hospital meets at least 80 percent of required staffing assignments.
- Preserve supporting data for each staffing report, including schedules, assignments, variances and explanations for deviations.
- Expanded Workers’ Compensation Benefits for Health Care Providers and Teachers Assaulted at Work
What Changed: Under the Workers’ Compensation Act, injured employees generally receive wage-replacement benefits equal to approximately 75 percent of their average weekly wage, subject to a statutory cap. The Act has expanded coverage for certain Connecticut employees. Effective October 1, 2026, certain health care employees, educators, board of education employees and related covered personnel who suffer total or partial incapacity because of a physical or negligent assault while performing job duties may be entitled to weekly compensation equal to 100 percent of average weekly earnings, with related medical expenses and lost wages for court appearances covered. Covered absences may not be charged against sick, vacation or personal leave.
Action Steps:
- Review incident-response procedures for workplace assaults and ensure HR, risk management and payroll understand when enhanced benefits may apply.
- Update leave-administration practices so qualifying absences are not deducted from accrued paid time off.
Municipalities and Contractors
- Municipal Deferred Retirement Option Plans
What Changed: Effective October 1, municipalities that do not participate in the Municipal Employees’ Retirement Fund may create a deferred retirement option plan for eligible service-retirement employees. Any plan must have a fixed participation period of no more than five years, a specified interest credit, actuarial certification that the plan is not expected to increase the municipal contribution rate, and an actuarial evaluation within four years.
Action Steps:
- For municipal employers, evaluate whether a deferred retirement option plan supports workforce planning and retention goals.
- Engage actuarial advisors before adopting a plan and document certification of no anticipated contribution-rate increase.
12. Retention of Service Contract Workers
What Changed: Effective July 1, 2027, successor contractors that assume certain service contracts or covered locations in Connecticut (e.g., large residential buildings, malls, hotels, transit facilities, office complexes, warehouses and distribution centers) must retain the predecessor contractor’s workers for at least 90 days. At the end of the 90-day period, the successor contractor must offer continued employment in writing to workers whose performance is satisfactory. However, a successor employer may decline to retain a worker if the worker’s prior performance or attendance would cause a reasonably prudent employer to terminate employment. The successor contractor may also reduce staffing if fewer employees are needed, provided reductions are made by seniority within job classifications. During the 90-day period, retained workers may only be discharged for just cause based on their own performance or conduct.
Penalties can be significant, including penalties ranging from $500 to $1,000 per day per employee for unlawful discharge, and $50 to $200 per employee per day for notice violations.
Action Steps:
- Require outgoing contractors to provide current employee rosters, job classifications, seniority dates, schedules, wage rates and performance or attendance records.
- Build a 90-day retention plan, including written offers, onboarding steps, supervision expectations and just-cause documentation.
- If fewer workers are needed, document the business reason and apply reductions by seniority within each job classification.
- Train managers not to terminate retained workers during the 90-day period without documented just cause and HR and legal review.
Electronic Monitoring
- Expansion of Electronic Monitoring Notice Requirements
What Changed: Effective October 1, all Connecticut employers who electronically monitor employees have expanded notice obligations to employees under the Electronic Monitoring Act. The Act continues to require advance written notice of the types of monitoring that may occur and now requires employers to identify the specific workplace locations where monitoring may occur and post notices in those locations.
The Act also requires employers to provide employees hired on or after October 1 with a plain-language statement before starting work that identifies prohibited activities that may be monitored without prior written notice under the Act’s misconduct exception. Under this exception, an employer with reasonable grounds to suspect serious misconduct (i.e., violation of law, violation of the rights of the employer or other employee, or creation of a hostile work environment) may use electronic monitoring to investigate such misconduct without providing prior written notice to the employee.
Employers do not need to disclose specific monitoring locations for airport premises or where the employer has reasonable grounds to monitor for security and employee safety purposes.
Noncompliance may result in penalties of up to $500 for the first offense, $1,000 for the second offense and $3,000 for the third and each subsequent offense.
Action Steps:
- Review current monitoring practices and document where monitoring may occur on the employer’s premises, such as reception areas, production floors, vehicles and computer workstations.
- Review and update notices to describe the types of monitoring and specific locations where monitoring may occur.
- Ensure notices are posted in conspicuous locations readily available to employees, including in the specific location where monitoring may occur.
- Prepare a plain-language statement for employees hired on or after October 1, 2026, that explains prohibited conduct that may be monitored without prior written notice under the Act’s misconduct exception.
- Employers with multi-state operations should also review whether Connecticut-specific updates should be coordinated with broader workplace privacy and monitoring policies.
Harris Beach Murtha’s Labor and Employment Practice Group will continue to monitor these laws and other Connecticut labor and employment legislation. Should you have questions or need advice regarding this or related matters, please reach out to attorney Patricia E. Reilly at (203 772-7733 and preilly@harrisbeachmurtha.com; attorney Eboné L. Luciano at (203) 772-7711 and eluciano@harrisbeachmurtha.com; or the Harris Beach Murtha attorney with whom you most frequently work.
This alert does not purport to be a substitute for advice of counsel on specific matters.
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, Providence, Rhode Island, and Newark, New Jersey.