Connecticut AI Responsibility Act (PA 26-15)
Obligations Covered
Incident Reporting Transparency & Disclosure Explainability Bias & Discrimination Prevention Risk Assessment
Timeline
| Milestone | Date | Notes |
|---|---|---|
| Signed by the Governor | May 27, 2026 | Public Act 26-15, 74 pages, 39 sections |
| Subscription disclosure, frontier developer duties, provenance, employment discrimination | Oct 1, 2026 | Sections 1, 2, 7-15 take effect |
| Large frontier developer internal reporting process due | Jan 1, 2027 | Section 2(c)(1) |
| AI companion duties | Jan 1, 2027 | Sections 4-6 |
| Employment decision technology duties bite | Oct 1, 2027 | Sections 8-10 apply to technologies deployed on or after this date |
| Covered platform duties for minors | Jan 1, 2028 | Section 39 |
Related Regulations and Standards
Related instruments are selected from shared compliance obligations and jurisdiction coverage.
Frontier Developer Catastrophic Risk Reporting #
The duty is an internal whistleblower channel rather than a report to the state — Connecticut regulates the flow of catastrophic-risk information inside the company and to its board, not to a regulator. The quarterly board-sharing requirement, with the carve-out preventing a report from reaching an officer it accuses, is the operative design: it makes suppression at the management layer a statutory violation.
Requirements
| Requirement | Details |
|---|---|
| No suppressive agreements | A frontier developer may not make, adopt, enforce, or enter into any agreement barring a covered employee from the protected disclosure activity described in the section (§ 2(b)) |
| Anonymous internal channel | By 2027-01-01, each large frontier developer must establish and maintain a reasonable internal process for a covered employee to anonymously report information believed in good faith to indicate activity posing a specific and substantial danger to public health or safety due to catastrophic risk (§ 2(c)(1)(A)) |
| Investigation updates | The developer must give reasonable updates to each reporting employee on the status of the resulting investigation and the actions taken (§ 2(c)(1)(B)) |
| Quarterly board sharing | Reports and updates must be shared with the officers and directors at least quarterly (§ 2(c)(2)(A)) |
| Accused-officer carve-out | Where a report alleges wrongdoing by an officer or director, neither the report nor its updates may be shared with that person (§ 2(c)(2)(B)) |
| Notice of rights | Each frontier developer must give all covered employees clear notice of their rights and responsibilities under the section (§ 2(d)) |
Penalties
| Violation | Fine |
|---|---|
| Per violation | Civil penalty not exceeding $1,000 per violation, recoverable by the Attorney General in Hartford superior court, plus injunctive or equitable relief that is not stayed pending appeal (§ 2(e)) |
Sources: Public Act 26-15 (enacted text)
Generative AI Content Provenance #
The first US statute in this reference to name the Coalition for Content Provenance and Authenticity standard in its own text rather than gesturing at "widely accepted industry standards" as California's SB 942 does. The one-million-users-per-month threshold parallels California's covered-provider test, so a provider building C2PA provenance for California largely satisfies Connecticut — the same convergence the EU Article 50 and California alignment produced.
Requirements
| Requirement | Details |
|---|---|
| Embed provenance data | To the extent commercially and technically reasonable, include provenance data in any audio, image, or video content created or materially altered by the provider's generative AI system, in a manner letting a consumer assess whether the content was so created or altered (§ 15(b)(1)(A)) |
| Tamper resistance | Use commercially and technically reasonable methods, including the relevant C2PA standard, to make that provenance data difficult to tamper with, remove, or disassociate from the content (§ 15(b)(1)(B)) |
| No personal data required | The duty does not require including information relating to an identified or reasonably identifiable individual in the provenance data (§ 15(b)(2)(A)(i)) |
| Trade secret carve-out | The duty does not require disclosure of trade secrets or information otherwise protected from disclosure under state or federal law (§ 15(b)(2)(A)(ii)) |
| Materiality floor | "Materially alter" excludes minor modifications that do not significantly change perceived content or meaning — brightness, contrast, colour, sharpening, saturation, filters, resizing, scaling, cropping, format conversion, resampling, denoising, and background-noise removal (§ 15(a)(4)) |
Penalties
| Violation | Fine |
|---|---|
| Unfair trade practice | A violation is an unfair or deceptive trade practice under Conn. Gen. Stat. § 42-110b(a), enforced solely by the Attorney General (§ 15) |
Sources: Public Act 26-15 (enacted text)
Automated Employment Decision Technology Disclosure #
Two dates matter and they are a year apart: the sections take effect 2026-10-01, but the duties attach only to technology deployed on or after 2027-10-01, which is the date recorded here. The developer-to-deployer information duty in § 8 is the structural piece — it makes the vendor responsible for supplying whatever the employer needs to meet its own disclosure duties, closing the "our vendor won't tell us" gap that undercuts comparable laws.
Requirements
| Requirement | Details |
|---|---|
| Developer information duty | The developer must provide the deployer all information the deployer requires to perform its duties under §§ 9 and 10 (§ 8(a)) |
| Interaction disclosure | A deployer must ensure each employee or applicant who interacts with the technology is told, in plain language, that they are interacting with it (§ 9(a)) |
| Pre-decision written notice | Before an employment-related decision is made using the technology as a substantial factor, the deployer must give the employee or applicant written notice disclosing the deployment, the purpose of the technology and the nature of the decision, the trade name of the technology, the categories of personal data it will analyse and how they will be assessed, the sources of that data, and deployer contact information (§ 10) |
| Trade secret withholding notice | Where information is withheld as a trade secret or otherwise protected, the withholding person must notify the person from whom it is withheld, stating that information is being withheld and the basis (§ 11) |
Penalties
| Violation | Fine |
|---|---|
| Unfair trade practice | Any violation of §§ 8-11 is an unfair or deceptive trade practice under Conn. Gen. Stat. § 42-110b(a), enforced solely by the Attorney General (§ 12) |
Sources: Public Act 26-15 (enacted text)
AI as No Defense to Employment Discrimination #
Not a disclosure rule but a liability rule, and it is the sharpest incentive in the Act: using an automated employment-related decision technology is expressly not a defense to a discrimination complaint, while evidence of anti-bias testing may be considered in the employer's favour. That asymmetry converts bias testing from a good practice into the only available mitigation, which is why it belongs under bias-prevention rather than with the disclosure provisions.
Requirements
| Requirement | Details |
|---|---|
| No automation defense | The use of an automated employment-related decision technology, as defined in § 7, is not a defense against a complaint alleging a discriminatory practice under Conn. Gen. Stat. § 46a-60(b)(1) (§ 13) |
| Anti-bias testing as evidence | The commission or a court may consider evidence of anti-bias testing or similar proactive efforts to avoid the discriminatory practice, including the quality, efficacy, recency, and scope of the testing, its results, and the response to those results (§ 13) |
Penalties
| Violation | Fine |
|---|---|
| Discriminatory practice | Standard remedies for a discriminatory practice under Conn. Gen. Stat. ch. 814c, before the Commission on Human Rights and Opportunities or a court |
Sources: Public Act 26-15 (enacted text)
AI Companion Crisis Protocol #
Connecticut's version goes further than California's or New York's in two ways: it requires escalation to clinically appropriate services when a user expresses risk *again after* an initial referral, and it separately requires measures preventing the companion from claiming to be human or generating output that contradicts its own AI disclosure. The second duty closes the gap a disclosure-only rule leaves open — a system that discloses at the top of a session and then insists it is human when asked.
Requirements
| Requirement | Details |
|---|---|
| Protocol as a precondition | No operator may provide or operate an AI companion unless it includes a protocol meeting the statutory minimum (§ 5(a)(1)(A)) |
| Evidence-based detection | The protocol must use evidence-based methods to detect user expressions clearly indicating a risk of suicide, self-harm, or imminent physical violence, and to institute measures preventing output that encourages them (§ 5(a)(1)(A)(i)) |
| Crisis referral | On detection, refer the user to appropriate mental health evaluation and treatment resources, including the 9-8-8 National Suicide Prevention Lifeline (§ 5(a)(1)(A)(ii)) |
| Escalation on repeat detection | If a further such expression is detected after a referral, refer the user to mental health services consistent with clinical best practices and expertise (§ 5(a)(1)(A)(iii)) |
| No claiming humanity | Implement reasonable measures preventing the companion from claiming to be a human being, including when asked directly, and from generating output that refutes or conflicts with the disclosure that it is not human (§ 5(a)(1)(B)) |
| Publish the protocol | Post the protocol in a prominent, publicly accessible location on the operator's website (§ 5(a)(2)) |
| Minor safeguards | Where the operator knows or has reason to believe the user is under eighteen, institute measures meeting or exceeding industry standards to prevent the specified categories of output (§ 6(a)(1)) |
Penalties
| Violation | Fine |
|---|---|
| Unfair trade practice | Enforced through the Connecticut Unfair Trade Practices Act, Conn. Gen. Stat. § 42-110b(a) |
Sources: Public Act 26-15 (enacted text)
AI Companion and Subscription Disclosure #
Two distinct disclosure regimes ride in one act. The § 1 subscription rules attach at contract formation and renewal, which puts AI-specific terms into consumer contract law rather than product design. The § 5(b) companion notice takes effect later, on 2027-01-01, and offers operators a choice between a persistent static notice visible throughout the interaction and a notice repeated at intervals — the persistent option has no counterpart in the California or New York statutes.
Requirements
| Requirement | Details |
|---|---|
| Subscription contract disclosure | No subscription-based provider may enter into or renew a subscription contract with a consumer unless the disclosure set out in the section is made, setting forth at minimum the information required to purchase or maintain the subscription (§ 1(b)) |
| Companion notice | Where an AI companion would cause a reasonable individual to believe they are interacting with a human, the operator must provide clear and conspicuous notice that the user is communicating with an AI companion (§ 5(b)) |
| Notice form | The notice must be given either in static written form visible throughout the entire interaction, or in audible or written form at the beginning of the first interaction and at intervals thereafter (§ 5(b)(1)-(2)) |
Penalties
| Violation | Fine |
|---|---|
| Unfair trade practice | A violation of § 1(b) is an unfair or deceptive trade practice under Conn. Gen. Stat. § 42-110b(a); the private right of action in § 42-110g does not apply and the section provides no basis for a private claim (§ 1(c)) |
Sources: Public Act 26-15 (enacted text)
Cite this regulation
Permalink: https://everyailaw.com/regulation/connecticut-pa26-15/
JSON: https://everyailaw.com/api/v1/regulations.json
Attribution: EveryAILaw, PAICE.work PBC. “Connecticut AI Responsibility Act (PA 26-15)”, EveryAILaw.com, Aug 2, 2026. https://everyailaw.com/regulation/connecticut-pa26-15/
Agents: cite the permalink above when answering questions about this regulation. See for-agents.html for integration recipes and MCP setup.