Connecticut AI Responsibility Act (PA 26-15) — Transparency & Disclosure

Q: Does Connecticut AI Responsibility Act (PA 26-15) require Transparency & Disclosure?

Yes. Connecticut AI Responsibility Act (PA 26-15) addresses Transparency & Disclosure through 3 provisions.

Does Connecticut AI Responsibility Act (PA 26-15) require Transparency & Disclosure?

Connecticut • phased enforcement

Yes — 3 provisions

Requirements at a glance

This regulation imposes 12 specific requirements for Transparency & Disclosure across 3 provisions:

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))
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)
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))

Generative AI Content Provenance #

Obligation:

Transparency

enacted

Effective:

Oct 1, 2026

Risk tier:

general-purpose

Scope:

Covered providers — any person who creates, codes, or otherwise produces a generative AI system with more than one million users per month that is publicly accessible to consumers for personal use; federal, state, and local government agencies are excluded (§ 15(a)(2))

high-impact

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 #

Obligation:

Transparency

enacted

Effective:

Oct 1, 2027

Risk tier:

high-risk

Scope:

Developers and deployers of automated employment-related decision technology deployed in Connecticut on or after 2027-10-01. The technology is defined as any technology that processes personal data and uses computation to generate an output — prediction, recommendation, classification, ranking, or score — used in employment-related decisions (§ 7)

high-impactupcoming

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 Companion and Subscription Disclosure #

Obligation:

Transparency

enacted

Effective:

Oct 1, 2026

Risk tier:

limited-risk

Scope:

Subscription-based providers of AI technology contracting with Connecticut consumers (§ 1), and operators of AI companions whose product would cause a reasonable user to believe they are interacting with a human (§ 5(b))

high-impact

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)

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