CT AI Responsibility and Transparency Act (CART)

Artificial Intelligence (AI) has become increasingly common in the workplace, including in recruiting, hiring, and general employee management, which may open businesses to unforeseen risks. Because of this, Connecticut has decided to address the issue head-on with the newly enacted Connecticut Artificial Intelligence Responsibility and Transparency Act (CART), as outlined in Public Act No. 26-15.

On May 27, 2026, Governor Ned Lamont approved Public Act No. 26-15, which provides a broad range of artificial intelligence and online safety provisions, some of which directly impact Connecticut employers using AI for employment-related decisions.

This law will officially be in effect starting October 1, 2026, with other effective dates happening later throughout the next couple of years, meaning that all Connecticut employers must not only be aware of the labor law updates made, but must also be prepared to update company policies and compliance efforts to mirror the new requirements.

To help summarize this recent addition to Connecticut's labor laws, this article will highlight the legislation and requirements employers must know, as well as a quick checklist to help stay organized. Here’s everything you need to know.

What Is the CT AI Responsibility and Transparency Act?

The Connecticut Artificial Intelligence Responsibility and Transparency Act, commonly referred to as the CART Act, generally includes legislation that affects consumers, online platforms, and AI developers, though there is substantial legislation that affects employers and AI use in the workplace.

Primarily, the provisions that affect employers focus on automated employment-related decision technology (AEDT), which refers to technology that processes personal data and uses AI tools to generate resources that can influence hiring decisions.

What’s critical for employers to know is that the use of AI tools is not banned outright; rather, the law establishes rules for potential discriminatory acts when AI tools are involved and requirements for employee transparency, whether related to the hiring process, layoffs, or collective bargaining.

Below are the main provisions under the CART Act that employers must adhere to:

Discrimination When Using AI Tools Under the CART Act

Beginning October 1, 2026, employers cannot use AI tools in the hiring process as a defense against employment discrimination claims. Businesses must evaluate how AI tools are used in the workplace to avoid any risk of employee discrimination.

The law does allow a court and the Connecticut Commission on Human Rights and Opportunities to “consider evidence of anti-bias testing or similar proactive efforts to avoid the discriminatory factor” when evaluating a claim; however, this should not be relied on. To help navigate difficult situations relating to AI tools and hiring, employers should reach out to an HR consulting service to proactively identify and take steps to address potential discriminatory outcomes before they happen.

AI Disclosure Requirements Beginning in 2027

Beginning October 1, 2027, employers using AI tools to assist in employment-related decisions must provide notices to applicants and employees in certain circumstances. If an individual interacts with the technology at any point in the process, the employers must disclose this in plain language. This includes a written notice before using AI tools to make or use as a substantial factor in making a decision.

The written disclosure must include the following:

A statement that the employee is using AI tools for employment purposes
The purpose of the AI tools used and the nature of its involvement in the decision
The trade name of the AI tools used
The personal data the AI technology will be assessing and how it does so
The sources of personal data
The employer’s contact information

Employers must take the time beforehand to review AI tools and their usage for HR related employment decisions.

Connecticut WARN Notices and AI

Beginning October 1, 2026, employers that are required to provide a written notice to the Connecticut Department of Labor under the federal Worker Adjustment and Retraining Notification (WARN) Act must also disclose whether employee layoffs are related to the employer’s use of AI tools or other major technological changes. This provision is an additional requirement to the federal WARN Act and does not replace it.

Employers that may have to mass-lay off employees or close plants should consider this as an extra step in the WARN Act compliance process.

AI and Collective Bargaining Agreements

Beginning October 1, 2026, the CART Act establishes protections for employees participating in collective bargaining. Employers may not use AI tools to modify or impair a collective bargaining agreement or the role of a designated employee organization.

Employers with unionized workforces should therefore consider how AI implementation could affect existing collective bargaining agreements and employee representation.

CT CART Act Compliance Checklist

Although many of the requirements do not take effect right away, employers should begin preparing well in advance to ensure compliance.

Here is a quick checklist to get you started:

Inventory AI Tools: Document the AI and automated decision-making tools your organization currently uses for recruiting, hiring, promotions, discipline, termination, performance, and other key employment-related decisions
Determine Which Tools Are Covered: Review which systems process personal data and produce generated outputs that can influence employment-related decision-making
Review AI Vendors: Determine what information vendors can provide about their platform, including the types and sources of personal data assessed and how the outputs are generated
Document Anti-Bias Efforts: Maintain records of any testing, monitoring, or other proactive measures used to identify and address potentially discriminatory outcomes from AI tools
Prepare Disclosure Procedures: Develop a process for notifying applicants and employees when they interact with AI tools and for providing the required written disclosures before employment-related decisions are made (before October 1, 2027)
Update WARN Procedures: Add a review step to applicable CT WARN notices to determine whether a mass layoff or plant closing is related to AI or another technology change (before October 1, 2026)
Review Collective Bargaining Obligations: For unionized workplaces, assess whether AI tools could affect bargaining agreements or the role of a designated employee organization

Frequently Asked Questions

Does the CT CART Act Ban Employers From Using AI in Hiring?

No, the CART Act does not prohibit employers from using AI or automated employment-related decision technologies. Instead, it establishes transparency and disclosure requirements and makes clear that an employer’s reliance on AI does not protect it from certain discrimination claims.

What Types of AI Tools May Be Covered by the CT CART Act?

The law primarily addresses automated employment-related decision technology (AEDT), which can include technology that processes personal data and produces predictions, recommendations, classifications, rankings, or scores that materially influence employment-related decisions. Employers should evaluate the specific capabilities and uses of each AI tool rather than assuming that every tool is covered.

Does the CART Act Apply to Employers With Unionized Employees?

Yes, the law includes provisions addressing collective bargaining agreements and designated employee organizations. Employers with unionized workforces should consider whether implementing AI technology could affect existing collective bargaining obligations.

What Should Employers Do If They Already Use AI in Their HR Processes?

Employers should begin by creating an inventory of AI tools currently used in recruiting, hiring, performance management, promotions, discipline, and other employment-related processes. They should then determine which systems may qualify as AEDT, review vendor information, document anti-bias efforts, and develop procedures for meeting future disclosure requirements.

Prepare Ahead of Time for Connecticut’s New AI Requirements

The CART Act adds another layer of compliance for employers that use or rely on AI tools throughout the employee lifecycle. These requirements emphasize transparency and accountability when AI tools influence employment-related decisions.

Before the first wave of requirements starts on October 1, 2026, Connecticut employers should begin auditing their current AI usage, documenting how automated systems influence employment decisions, and working with technology vendors to prepare for future requirements as enforcement evolves.

Employers operating in Connecticut that need an extra hand when it comes to state requirements should reach out for HR consulting services from Connecticut payroll and HR experts.