EveryAILaw.comDoes Connecticut AI Responsibility Act (PA 26-15) require Incident Reporting?
Connecticut • phased enforcement
Yes — 1 provision
Requirements at a glance
This regulation imposes 6 specific requirements for Incident Reporting across 1 provision:
- 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))
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)