EveryAILaw.comDoes Connecticut Consumer Protection Omnibus, AI provisions (PA 26-100) require Transparency & Disclosure?
Connecticut • enforcing
Yes — 1 provision
Requirements at a glance
This regulation imposes 3 specific requirements for Transparency & Disclosure across 1 provision:
- Written notice before contract or payment — No subscription-based provider may enter into or renew a subscription, or collect any fee for an initial subscription or renewal, unless it has given the consumer a written notice of the key terms and conditions and the consumer has given written notice accepting them (§ 46(b)(1))
- Initial-subscription content — The notice must give material information sufficient for a reasonable consumer to decide whether to purchase or maintain the subscription, including any quantitative or qualitative limitations the provider may impose (tokens, images generated or modified, transcription services, and limits imposed in response to consumer conduct) and whether the provider has discretion to limit or eliminate access to, or reduce the quantity or quality of, any functionality (§ 46(b)(2)(A))
- Renewal content — For a renewal, the notice must state any such limitations or discretion that the provider will be able to exercise for the first time in the renewal term, or that applied in the preceding term but have been modified (§ 46(b)(2)(B))
Generative AI Subscription Disclosure
Enacted eleven days after PA 26-15 § 1 and effective the same day, this is Connecticut's second AI subscription disclosure rule. Section 46 is narrower in actors (generative AI, one-million-user threshold, creators only) and broader in required content (usage limits and functionality discretion, with renewal re-disclosure) than PA 26-15 § 1, which reaches any AI technology subscription. Neither section references the other; both apply. "Generative artificial intelligence system" is defined as technology using machine learning to generate images, audio or video, and includes systems using deep learning, natural language processing or comparable techniques (§ 46(a)(2)).
Requirements
| Requirement | Details |
|---|---|
| Written notice before contract or payment | No subscription-based provider may enter into or renew a subscription, or collect any fee for an initial subscription or renewal, unless it has given the consumer a written notice of the key terms and conditions and the consumer has given written notice accepting them (§ 46(b)(1)) |
| Initial-subscription content | The notice must give material information sufficient for a reasonable consumer to decide whether to purchase or maintain the subscription, including any quantitative or qualitative limitations the provider may impose (tokens, images generated or modified, transcription services, and limits imposed in response to consumer conduct) and whether the provider has discretion to limit or eliminate access to, or reduce the quantity or quality of, any functionality (§ 46(b)(2)(A)) |
| Renewal content | For a renewal, the notice must state any such limitations or discretion that the provider will be able to exercise for the first time in the renewal term, or that applied in the preceding term but have been modified (§ 46(b)(2)(B)) |
Penalties
| Violation | Fine |
|---|---|
| Unfair trade practice | A violation of § 46(b) is an unfair or deceptive trade practice under Conn. Gen. Stat. § 42-110b(a), enforced solely by the Attorney General; the § 42-110g private right of action does not apply and the section creates no private right of action (§ 46(c)) |