Introduction

The 2026 session of the Connecticut General Assembly adjourned on May 6, 2026. As an election-year session, it was relatively brief, yet the legislature continued its trend of enacting omnibus bills—sweeping measures that consolidate broadly related provisions under a single legislative vehicle. In part one of our summary, we discussed Public Act 26-12.  This article provides a comprehensive summary of the remaining key labor and employment legislation enacted during the 2026 session. Employers (both public and private sector) and their counsel should review these developments carefully and assess their compliance obligations in the months ahead.

Public Act 26-1: The First Omnibus Bill

Public Act 26-1 is an omnibus “emergency certification” bill signed by the Governor on March 3, 2026. Formally titled “An Act Concerning the Reallocation of Certain State Funds and Various Provisions Relating to Education, Public Safety, General Government, Elections, Intermediate Care Facilities and Warehouse Distribution Centers,” the Act addresses a variety of topics that, in many cases, represent provisions that failed to advance in prior sessions of the General Assembly.  It includes several provisions related to employment.

CMERS Study for Police Officers and Firefighters

The Act requires the Comptroller to study how a municipality that does not maintain a defined benefit pension plan for its police officers and firefighters can successfully transition those employees into the Connecticut Municipal Employees’ Retirement System (CMERS) or a comparable plan. The Comptroller then must submit a report with the results of this study to the General Assembly’s Labor and Public Employees Committee by January 1, 2028.

Warehouse Worker Quota Protections

The Act introduces significant new protections for employees at qualifying “warehouse distribution centers.” The Act applies where an entity employs or exercises control over the wages, hours, or working conditions of 250 or more employees at a single warehouse distribution center in the state, or 1,000 or more employees at one or more such centers statewide.

Quota Disclosure Requirements. Employers must provide each covered employee, no later than August 1, 2026, with a written description of each performance quota to which the employee is subject, along with the potential adverse employment actions that may result from a failure to meet the quota. Employers must also provide advance notice of any changes to quotas. No adverse action may be taken against an employee for failure to meet a quota that has not been properly disclosed (or otherwise is in violation of the provisions of this Act).

Substantive Limitations on Quotas. Quotas may not prevent an employee from complying with duty-free meal period laws or from using bathroom facilities, including reasonable travel time to and from those facilities. No quota may set a performance standard that measures total output over an increment shorter than the employee’s workday, and no quota may be based solely on ranking an employee’s performance relative to other employees.

Recordkeeping and Data Access. Employers must establish, maintain, and preserve contemporaneous records of each employee’s individual work speed data, aggregated work speed data for similarly situated employees at the same center, and the written quota descriptions provided to each employee. These records must be maintained for three years (although these recordkeeping requirements do not apply if the employer does not assign/require quotas or collect or analyze work speed data). Any current or former employee who believes that meeting a quota caused a violation of their rights may request a written description of each quota to which they were subject, along with their personal work speed data and the aggregated data for similar employees for the most recent 90 days. Employers must respond as soon as practicable but no later than 10 days after the request.

Anti-Retaliation Protections and Private Right of Action. The Act creates a rebuttable presumption of unlawful retaliation if an employer discriminates, retaliates, or takes any adverse action against an employee within 90 days after the employee (1) initiates the employee’s first request in a calendar year for quota or work speed data, or (2) makes a complaint alleging a violation of these provisions to the Labor Commissioner. Aggrieved employees may seek redress through a private right of action in the Superior Court.

Public Act 26-68: The Budget Implementer

Public Act 26-68, originally Senate Bill 1 (“An Act Concerning Affordability”), grew into a 745-page budget implementer signed by the Governor on May 26, 2026. While primarily a fiscal measure, it includes several provisions of significant interest to the labor and employment community (and which are not really budget related).

Hours Worked and Employer Security Screenings

Effective October 1, 2026, the Act modifies the definition of “hours worked” under Connecticut’s wage and hour laws to include time spent by employees in security screenings required by an employer.

Workplace Heat Safety Task Force

The Act establishes a task force to study heat safety in the workplace, including best practices to prevent employee exposure to heat illness and other states’ laws and regulations on heat safety standards. The task force must submit its report with findings and recommendations to the General Assembly’s Labor and Public Employees Committee by January 1, 2027.

Increased Compensation for Labor Boards

The Act increases the per diem rate for regular and alternate members of the State Board of Labor Relations from $150 to $300 per day and increases compensation for State Board of Mediation and Arbitration members.

Hazardous Duty Disability Benefits for Health Care Providers

The Act provides that health care providers employed at state-operated health care facilities or institutions are eligible for state employee hazardous duty disability benefits if they are assaulted while performing their duties.

Studies and Reports

The Act mandates several studies of importance to employers and policymakers. It creates a working group to study a payroll tax program for state employees, with a report due by January 1, 2027. It requires the Office of Policy and Management (OPM) to submit a plan ensuring that technological advancements augment worker capability rather than render it obsolete, including mechanisms for reinvestment, collaborative productivity models, and a “workforce and productivity gap contribution” formula. It also requires the Labor Commissioner to study the rights of workers “under economic pressure,” with a report due by January 1, 2028.

The Connecticut Option: Public Health Care Feasibility

The Act authorizes OPM to study the feasibility of establishing a “Connecticut Option” (i.e., a public option) health care program and to design a plan for transitional health care premium assistance to offset 2027 Access Health CT premium and cost-sharing increases. OPM must issue interim and final reports to the General Assembly by January 15, 2027 and January 31, 2028, respectively, and must hold stakeholder engagement meetings to develop the program.

Public Act 26-15: Online Safety and Artificial Intelligence

Public Act 26-15 is a comprehensive online safety and artificial intelligence measure with several labor and employment implications.

AI Whistleblower Protections. The Act creates new whistleblower protections for employees of “frontier developers”—companies training large-scale AI foundation models. Such employers may not discharge, discipline, or penalize employees for engaging in protected whistleblower activity. Covered employees who report activities posing “catastrophic risk” to public health or safety are protected from retaliation. Large frontier developers must establish internal anonymous reporting processes by January 1, 2027, provide clear notice of employee rights, and face civil penalties of up to $1,000 per violation, enforceable by the Attorney General.

Automated Employment Decision Technology. The Act regulates “automated employment-related decision technology”—technology that processes personal data and uses computation to generate outputs serving as a “substantial factor” in employment decisions. Deployers must disclose to employees and applicants in plain language that they are interacting with such technology and must provide pre-decision written notice including the technology’s purpose, trade name, categories and sources of personal data analyzed, and deployer contact information. Developers must provide deployers with all information necessary to fulfill compliance obligations. Trade secret protections apply, but parties must disclose that information is being withheld. Violations are enforceable solely by the Attorney General as unfair or deceptive trade practices, with a 60-day cure period for violations before December 31, 2027. There is no private right of action.

Anti-Discrimination Law Amendments. The Act amends Connecticut’s anti-discrimination statutes to clarify that the use of automated employment-related decision technology is not a defense against a discrimination complaint. Courts and the Commission on Human Rights and Opportunities may, however, consider evidence of anti-bias testing or proactive measures when evaluating claims.

WARN Act AI Disclosure. Employers issuing WARN Act notices to the Labor Department must disclose whether the layoffs are related to the employer’s use of artificial intelligence or another technological change.

Workforce Impact Programs. The Act directs UConn’s Institute for Municipal and Regional Policy to study AI’s impact on the workforce, requires the Board of Regents to establish a Connecticut AI Academy, and expands the workforce development account and technology talent pipeline programs to include AI and quantum computing fields.

Additional Acts of Interest

Public Act 26-73: An Act Concerning The Electronic Surveillance of Employees, which takes effect on October 1, 2026, requires employers engaging in electronic monitoring to include in their required written notices the specific workplace locations where monitoring may occur, to post notices at those specific locations, and to provide new employees with a plain-language statement of prohibited activities subject to monitoring without prior notice (as per the current exceptions in the electronic monitoring statutes for providing such notice). The Act further provides that an employer is not required to disclose the specific locations where it is electronically monitoring its employees if the employer has reasonable grounds to conduct such monitoring for security and employee safety.  

Public Act 26-89: An Act Concerning Electronic Surveillance Devices and Systems and Self-service Kiosks in Employee Lounges, which takes effect on October 1, 2026, creates an exception to electronic monitoring/surveillance restrictions for self-service kiosks operated by third-party vendors in employee lounges, provided that such monitoring systems do not record sound and only capture the checkout and display areas. The Act defines a "self-service kiosk" as an interactive, stand-alone terminal that allows individuals to independently scan and purchase items for sale. Any third-party vendors 1) shall maintain sole custody of any video collected by such surveillance and 2) may not release or provide access to any portion of such video except where otherwise required by law (or permitted by the Act). In this regard, the Act provides that no employer shall request to view any such video or use any such video in a disciplinary action, except where there has been an alleged theft by an employee reported by a third-party vendor. 

Public Act 26-139: Education Statute Revisions.  This Act allows retired parole officers to provide armed security services in public schools, with disqualification for officers terminated due to disciplinary action, those who left employment during an investigation, or retired police officers dismissed for malfeasance or serious misconduct. The Act also revises disclosure requirements during the hiring of prospective school employees, expanding obligations to include pending allegations involving injury or risk of injury to children and removing the exemption for investigations resulting in unsubstantiated findings.

Special Act 26-34 establishes a task force to study causes of undue delay in workers’ compensation claims by police officers and firefighters, with a report due by January 1, 2027.

Public Act 26-145 requires the Commissioner of Labor, by January 1, 2027, to create and maintain a centralized webpage on the DOL website with workforce development resources, job training information, and career counseling links.

Special Act 26-31 requires the Comptroller to study the feasibility of providing stipends to members of the Connecticut Civil Air Patrol when absent from work for emergency response or required training.

Public Act 26-17 authorizes the Comptroller to withhold payment to contractors or subcontractors subject to a stop work order for prevailing wage violations until compliance is achieved.

Public Act 26-99 modifies the membership of the Governor’s Workforce Council to comply with federal requirements that a majority of appointments be business representatives, increasing the number of such appointments from 24 to 30.

Public Act 26-83 modifies reporting requirements for the Firefighters Cancer Relief Fund, consolidating two annual reports into one and requiring submission to the Labor and Public Employees Committee.