On May 11, 2026, Governor Ned Lamont signed Public Act 26-12, a sweeping piece of legislation that expands certain existing employment-related obligations and creates several new requirements affecting workplaces across the state. The new and expanded laws affect both public and private sector employers, and address a wide range of employment issues, including reasonable accommodations, pay transparency, promissory notes, wage and hour compliance, and labor peace agreements, as discussed below.

Employers should review these changes, assess their potential impact on existing workplace practices, and revise policies, procedures, and agreements as needed to ensure compliance.

Workplace Notice Requirements for ADA Accommodation Rights

Effective October 1, 2026, employers must provide employees with written notice of their rights to reasonable workplace accommodations for a disability under the Americans with Disabilities Act (ADA). This notice must be provided to: (1) new employees at the start of employment; (2) existing employees within 120 days of October 1, 2026; and (3) within 10 days after an employee notifies the employer of a disability. The law does not specify to which employers it applies, but the reference to the ADA, rather than Connecticut’s corollary workplace accommodations statute, suggests that the ADA’s 15-employee threshold would be applicable. Guidance on this question may come when the Labor Commissions adopts regulations concerning this notice requirement.

Employers may satisfy this requirement by displaying a poster prepared by the Labor Commissioner in a conspicuous location accessible to employees at the workplace. Also, effective October 1, 2026, the Labor Commissioner is required to post ADA-related information on the Labor Department’s website, including the definition of a disability and its relationship to reasonable workplace accommodations. This information must be downloadable for employers to display at their workplaces and must be available in both English and Spanish. The Labor Commissioner may adopt regulations establishing additional requirements regarding the manner in which employers must provide such notice.

 Accommodations for Nursing Employees

 Connecticut has expanded lactation accommodation requirements, mandating employers to provide reasonable breaks for nursing employees. Effective October 1, 2026, employers must provide reasonable break time, in addition to such employee’s scheduled breaks, for employees to express milk. Previously, the law protected lactation breaks at the employee’s discretion, without specific obligations on employers to provide additional break times. The new law does not specify whether the breaks must be paid, but state and federal laws should be reviewed for guidance regarding this issue.

Pay Transparency and Pay-Code Requirements

Pay Transparency

Effective October 1, 2026, employers will be required to provide more detailed compensation information to both applicants and employees. Specifically, employers must include in all internal and public job postings the wage or wage range for the position, along with a general description of benefits. “Benefits” are defined broadly to include health insurance, retirement benefits, fringe benefits, paid leave, and other non-wage compensation.

If a position is not posted, employers must provide the wage range and benefits description at (1) the applicant’s request or (2) prior to any discussion or offer of compensation. For current employees, employers must provide the wage range and benefits description upon hire, a change in position, and upon the employee’s first request.

The statute also clarifies that a wage range must reflect a good-faith range established by the employer. Employers may continue to rely on existing benchmarks such as internal pay scales, previously established ranges, actual compensation for comparable roles, or budgeted compensation.

Notably, these requirements apply not only to positions performed in Connecticut, but also to positions performed outside the state if the employee reports to a Connecticut-based supervisor, office, or worksite. Employers should review and update their job postings, job posting templates, and internal procedures for responding to compensation inquiries.

Pay Codes

Also effective October 1, 2026, employers with 100 or more employees (including state and local governmental entities) must develop and maintain a pay-code guide covering overtime codes and commonly used pay codes. Examples of such differentials include shift, on-call, hazard, call-back, weekend or holiday, and geographic pay variations. If applicable, the guide must include at least ten pay codes.

The guide must be:

• Posted on the employer’s website (if one exists) in English, Spanish, and other commonly spoken employee languages;
• Updated whenever new relevant pay codes are added; and
• Accompanied by contact information for handling employee questions or disputes regarding pay calculations.

Employers must provide employees with the website address for the guide at hire and include it on wage statements. Alternatively, employers may provide a written copy in English and the employee’s primary language. Any employer using a third-party payroll provider may rely on a compliant guide prepared by the vendor.

Employment Promissory Notes

Effective October 1, 2026, the state’s prohibition on employment promissory notes will apply to all employers. Previously, it applied only to employers with 26 or more employees. The law prohibits agreements that, as a condition of employment, require employees to repay money if the employee leaves employment before a specified period, including arrangements that are framed as training reimbursements or other similar repayment obligations.

The statute provides for several exceptions, including:

• Repayment of sums advanced to the employee;
• Payments for property sold or leased to the employee;
• Certain agreements affecting educational personnel;
• Agreements negotiated through a collective bargaining representative.

Employers should carefully review their offer letters, training repayment provisions, relocation agreements, tuition arrangements, and similar documents for compliance. 

General Contractor Liability for Unpaid Wages by Subcontractors

For construction contracts entered into on or after January 1, 2027, general contractors will be jointly and severally liable for any unpaid wages owed to an employee of a subcontractor. The law applies only to construction, renovation or rehabilitation projects in the state. Public works contracts and other projects involving any state or federal agency or department are expressly excluded. A similar law already exists for public works projects.

At least 30 days prior to initiating an action against a general contractor, employees must provide notice to the general contractor of the subcontractor’s alleged violation describing the general nature of the alleged violation. However, employees who have previously notified a general contractor of prior or similar alleged violations are not required to provide advance notice to the general contractor.

The law permits general contractors to include in a contract with a subcontractor a provision establishing a remedy for violations, such as that any unpaid wages may be paid from the amount withheld for retainage under the contract. However, such provisions do not waive or release liability for unpaid wages against a general contractor and employees may still bring an action for violations against either or both the general contractor and the subcontractor. This potential remedy poses challenges, given that the law allows employees to bring a wage claim two years later, or, in some cases, three years later. Also, a general contractor’s ability to verify that wages have been paid correctly could be difficult in light of the fact that wage rates can vary dramatically for these construction projects, as they may not (and likely do not) involve prevailing wages.

Prevailing Wage Amendments

Beginning October 1, 2026, employers engaged on projects subject to Connecticut’s prevailing wage laws must complete daily records of each person performing the work of a mechanic, laborer or worker on projects subject to those laws. The daily records must include:   

• The name and location of the project;
• The date of work performed;
• The name, signature, and trade license number of each covered individual; and
• The arrival and departure time of each covered individual.

In addition to recording the information, employers must also preserve the data and submit reports weekly to the contracting agency or the Department of Economic and Community Development, or to the developer of the project. Importantly, those records are considered a public record subject to inspection under the Connecticut Freedom of Information Act.

Employers that fail to comply with the new filing requirement may be subject to imprisonment, fines up to $500, or both.

Reemployment of Service Contract Workers

 Beginning July 1, 2027, employers that take over service agreements at defined “covered locations,” engage a successor services provider, or receive property in a sale or transfer must retain a terminated contractor’s employees for at least 90 days. Under the law, “covered locations” include the following:

• Multifamily residential buildings or complexes with fifty or more units;
• A commercial center or complex or office building occupying more than 75,000 square feet;
• Municipal office buildings or facilities;
• Public or nonpublic schools and independent higher education institutions;
• Cultural centers or complexes (e.g., museums, convention centers, arenas, performance halls);
• Shopping malls;
• Bank branches;
• Industrial sites, warehouses, distribution centers;
• Pharmaceutical labs; and
• Airports and train stations.

The retention requirements apply to all employers with two or more employees, including municipal and local governments and the state. During the initial 90-day period, an employer may not discharge, without just cause, any retained employee. After the 90-day period, the employer must provide employees with a performance evaluation and, to the extent the employee’s performance is satisfactory, offer the employee continued employment under the terms and conditions established by the successor employer, or as required by law. 

Within the initial 90-day period, an employer may not terminate a predecessor employer’s worker without “just cause,” which the law provides “shall be determined solely by the performance or conduct of the particular employee.” A predecessor employer’s worker may also be terminated by a successor employer if the predecessor employer’s performance and attendance records would “lead a reasonably prudent employer to terminate that employee.” Additionally, if, at any time, an employer determines that fewer employees are required to perform the services under a successor service contract, or services at the purchased or acquired property, the employer must retain employees based on seniority determined by the employees’ total length of service at the affected site or sites. During the initial 90-day period, employees who are not retained must be added to a preferential hiring list of employees eligible for recall if more workers are needed.

Successor employers that fail to retain or discharge workers in violation of the law will be subject to fines between $500 to $1,000 per employee for each day the violation continues. Employees who are not retained or who are discharged in violation of the law may file a complaint with the Department of Labor or a lawsuit in the Superior Court. Prevailing plaintiffs may be awarded back pay, benefits, reinstatement, compensatory damages, and attorneys’ fees and costs.

Employers that plan to take over active service contracts or acquire property with existing service workers should prepare to incorporate this retention framework into their planning and operations. Additionally, employers should be prepared for preemption challenges to this new law based on existing displaced worker and service contract retention laws. In states where similar laws have passed, employers have argued that they are preempted by the federal National Labor Relations Act (NLRA). Although courts have thus far rejected those challenges, the issue is far from settled and should be monitored carefully.

Cannabis-Related Workforce Provisions

Labor Peace Agreements

Effective October 1, 2026, the law requires certain cannabis licensees, including dispensary facilities and producers, to enter into labor peace agreements with bona fide labor organizations as a condition of final license approval. These agreements generally prohibit employer lockouts and union picketing, work stoppages, or boycotts. Each agreement must include a provision requiring final and binding arbitration as the exclusive remedy for disputes.

We note that recent litigation has challenged state-mandated labor peace agreement requirements on federal preemption grounds. In one New Jersey case, an employer argued that the state’s cannabis labor peace agreement mandate was preempted by the NLRA. Although the federal court declined to immediately block enforcement, it allowed the challenge to proceed and found that employer had shown a likelihood of success on the merits of its preemption argument. Similar challenges have also been brought against New York’s Marijuana Regulation and Taxation Act, with cannabis retailers arguing that mandatory labor peace agreements unlawfully intrude on federal authority over union organizing.

Gratuities and minimum wage

Separately, the legislation provides that gratuities may not be counted toward satisfying minimum wage obligations for employees of cannabis establishments. As a result, employers in this industry must ensure that employees receive the full minimum wage exclusive of tips.