Warden Watch

Connecticut: Automated Employment Decision Technology Provisions of the Online Safety Act (Public Act 26-15 / SB 5)

ConnecticutLegislationPhased application

Connecticut Public Act No. 26-15 is a broad technology regulation establishing rules for artificial intelligence, deepfakes, and online safety. Crucially for HR and recruitment teams, the law regulates the use of automated employment-related decision technology (AEDT) in hiring, promotion, discipline, and discharge decisions involving Connecticut residents. It requires employers to provide plain-language disclosures when candidates interact with AI systems and mandates detailed written notices before using an AEDT as a substantial factor in employment decisions. These notices must explain the tool's purpose, data sources, and assessment methods. Furthermore, the law stipulates that using automated technology is not a defense against employment discrimination claims, strongly incentivizing deployers to conduct proactive anti-bias testing. While the core duties fall on deployers, providers must supply their customers with the necessary information to fulfill these notice requirements, unless they contractually assume the deployer's compliance duties.

Impact

What this means for HR and vendors

HR and recruitment teams

HR teams may need to overhaul their candidate and employee communication processes when using automated employment decision tools. Organizations should ensure they provide a clear disclosure whenever individuals interact directly with AI and issue a detailed written notice before making employment decisions substantially influenced by an AI tool. This increases the importance of working closely with vendors to understand exactly what data is being used and proactively conducting anti-bias testing to defend against potential discrimination claims.

HR technology vendors

HR technology providers have direct legal duties to supply deployers with all necessary information to meet the state's disclosure and notice requirements. Providers must document how their automated decision tools work, the categories of personal data processed, and how that data influences outcomes. Alternatively, providers can enter into binding contracts to legally assume the deployer's transparency duties.

Key obligations

What organizations need to do

Practical obligation briefings focused on what the requirement is, who it applies to, when it applies and what teams should consider doing.

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This page is regulatory intelligence only. Organizations should seek guidance from legal counsel before making compliance decisions.

Employment-focused extraction

This may be part of wider regulation. The Warden Watch extracts and displays the parts relevant to employment, HR and recruitment decision-making.

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