Connecticut Public Act No. 26-15 (Substitute Senate Bill No. 5), the state's omnibus AI and online-safety statute, applies its first core private-sector duties from October 1, 2026, with the Connecticut Attorney General as the sole enforcer of the consumer-protection layer. The Act was signed by the Governor on May 27, 2026 and staggers subscription AI, frontier-developer and employment-AI obligations through January 1, 2028.
From October 1, 2026, subscription-based AI providers must give Connecticut consumers written key-term disclosures and obtain written acceptance before paid subscriptions, frontier model developers training foundation models above 10^26 FLOP must post covered-employee notices and bar retaliation for protected whistleblowing, and Connecticut employers cannot rely on automated employment-related decision technology (AEDT) as a defense to C.G.S. §46a-60 discrimination complaints. Subscription-AI disclosure failures are CUTPA unfair or deceptive practices enforced solely by the Attorney General, frontier-developer violations carry civil penalties up to USD 1,000 per violation, and employers lose the AEDT defense to section 46a-60 discrimination claims.
- Deadline : October 1, 2026 (the subscription-AI, frontier-developer and AEDT obligations apply)
- Who : subscription AI providers, frontier model developers above 10^26 FLOP doing business in Connecticut, and Connecticut employers using AEDT in hiring
- What : written key-term disclosures with consumer acceptance, frontier whistleblower and employee-notice duties, and removal of the AEDT discrimination defense
- Otherwise : CUTPA Attorney-General enforcement with no private right of action, civil penalties up to USD 1,000 per frontier violation, and loss of the AEDT defense
- Official source : Public Act No. 26-15 (SB 5), full text (PDF)
What is due on October 1, 2026
Three obligations take effect on October 1, 2026. Section 1 requires subscription-based AI providers to give Connecticut consumers written key-term disclosures and obtain written acceptance before entering or renewing a paid AI subscription, enforced as a CUTPA unfair or deceptive practice solely by the Attorney General. Section 2 requires frontier developers training foundation models above 10^26 FLOP to post covered-employee notices and bar retaliation against protected whistleblowing, and large frontier developers with over USD 500 million in gross revenue to maintain anonymous catastrophic-risk reporting channels by January 1, 2027. Section 13, amending C.G.S. §46a-60, confirms that AEDT use cannot be relied on as a defense to unlawful discriminatory-practice complaints.
Further duties follow on three later dates.
| Date | What applies |
|---|---|
| October 1, 2026 | Subscription AI disclosures, frontier-developer duties, AEDT defense amendment |
| January 1, 2027 | AI companion protocols and under-18 protections; large-frontier catastrophic-risk reporting channels |
| October 1, 2027 | AEDT developer information-sharing and deployer disclosure duties |
| January 1, 2028 | Covered-platform youth online-safety duties |
Who is covered
Section 1 covers providers offering paid AI subscriptions to Connecticut residents. Section 2 covers frontier developers training foundation models above 10^26 FLOP doing business in Connecticut, with a higher tier for large developers above USD 500 million in gross revenue. Section 13 covers Connecticut employers using AEDT in hiring or employment management.
What to do before October 1, 2026
- Stand up the written key-term disclosure and obtain written consumer acceptance before any new or renewed paid AI subscription (Section 1)
- Post the covered-employee notices required of frontier developers and adopt an anti-retaliation policy for protected whistleblowing (Section 2)
- For large frontier developers, build the anonymous catastrophic-risk reporting channel before January 1, 2027 (Section 2)
- Audit AEDT use in hiring against C.G.S. §46a-60 discrimination liability, as AEDT cannot be relied on as a defense (Section 13)
- Confirm the FLOP and revenue thresholds to determine frontier-developer and large-frontier status (Section 2)
What happens otherwise
Subscription-AI disclosure failures are CUTPA unfair or deceptive practices enforced solely by the Connecticut Attorney General, with no private right of action. Frontier-developer violations carry civil penalties up to USD 1,000 per violation. Employers lose the AEDT defense to section 46a-60 discrimination complaints. Continuous per-jurisdiction monitoring surfaces each applicability date as it publishes.
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