Back in May, we published a detailed breakdown of Connecticut’s Omnibus Workforce Bill (Public Act No. 26-12). With October 1, 2026 just around the corner, this post serves as a practical compliance reminder. Several key provisions take effect on that date, and employers should be taking concrete steps now to prepare.

Key Provisions Taking Effect October 1

Expanded Wage Transparency Requirements

Connecticut already had wage transparency requirements on the books. The bill strengthens them significantly. Starting October 1, employers must:

• Provide applicants with the wage range and a general description of benefits before any discussion of compensation or an offer – not just “prior to or at the time” of an offer, as was previously required.
• Provide employees the wage range and benefits description at hiring, upon a change in position, and on first request. 
• Disclose in all internal and public job advertisements the wages or wage range and a general description of benefits for the position. 
• The definition of “wage range” now means the range an employer “sets in good faith,” which may reference any applicable pay scale, previously determined range, actual range for comparable current employees, or the employer’s budgeted amount. “Benefits” is newly defined to mean health insurance, retirement benefits, fringe benefits, paid leave, and any other non-wage compensation offered with a position.

Ban on Employment Promissory Notes (Training Repayment Agreements)

As of October 1, no employer may require, as a condition of employment, any employee or prospective employee to sign an employment promissory note. The term is broadly defined to include any instrument requiring an employee to pay the employer if the employee leaves before a stated period, including agreements framed as training reimbursement. Any such note executed on or after October 1 is void as against public policy.

There are limited exceptions: agreements requiring repayment of sums actually advanced, payment for property sold or leased to the employee, sabbatical leave terms for educational personnel, and agreements under a collectively bargained program.

Critically, the prior law limited this prohibition to employers with 26 or more employees. That threshold has been eliminated. The ban now applies to any person engaged in business. 

ADA Reasonable Accommodation Notice Requirements

Employers must now provide written notice to employees of their right to reasonable accommodations for a disability under the ADA. Specifically, employers must provide this notice to:

1. New employees at the commencement of employment;
2. Existing employees within 120 days of October 1, 2026 (i.e., by late January 2027); and
3. Any employee who notifies the employer of a disability, within 10 days of such notification. 

Employers may comply by displaying a poster created by the Labor Commissioner in a conspicuous, employee-accessible location at the workplace. The Labor Department is also required to post downloadable information on its website in both English and Spanish. 

Enhanced Lactation Accommodation Protections

The bill shifts Connecticut’s existing lactation accommodation law from a permissive framework to a mandatory one. Employers must now affirmatively provide reasonable break times for employees to express breast milk or breastfeed on site, in addition to scheduled breaks.

Employers must make reasonable efforts to provide a private room (other than a toilet stall), near a refrigerator or portable cold storage device, and with access to an electrical outlet, absent undue hardship. The definition of “employer” is broad: any person engaged in business with one or more employees, including the state and its political subdivisions.

Employers may not discriminate against, discipline, or take any adverse action against an employee for exercising rights under this section. 

Pay Stub Transparency for Large Employers

Employers with 100 or more employees must now create and maintain a guide for pay codes covering overtime and commonly used pay differentials (e.g., shift, on-call, hazard, call-back, holiday/weekend, and geographical differentials). Key requirements:

• The guide must include at least 10 pay codes (if applicable) and be posted on the employer’s website in English, Spanish, and the other most common languages spoken by employees. 
• The guide must include contact information for the designated office or individual handling employee disputes about pay calculations. 
• Employers must provide the web address of the guide to employees upon hire and include it on each pay stub. 
• Employers who use a third-party payroll service that provides a satisfactory guide are deemed in compliance, and the law does not require an employer to create a website if it does not already maintain one, or to establish new pay codes. 

Workers’ Compensation Amendments

The bill also makes workers’ compensation changes effective October 1, including 100% wage replacement for injuries caused by an employer’s violation of a cited and unabated safety regulation, and enhanced compensation for assaults on healthcare workers and educators.

Enforcement Risks and Penalties

Employers should not treat these provisions as aspirational. Several carry real enforcement teeth:

• Wage transparency violations are subject to a private right of action with a two-year statute of limitations. Remedies include compensatory damages, attorney’s fees, costs, and equitable relief. 
• Employment promissory notes executed in violation of the ban are void as against public policy, and the invalidity of the note does not affect other provisions of the employment agreement. 
• Service contractor employee retention violations (effective July 1, 2027) carry penalties of $500–$1,000 per employee per day, and notice violations carry penalties of $50–$200 per employee per day. Employees may also bring private suits for back pay, reinstatement, compensatory damages, and attorney’s fees. 

What Employers Should Be Doing Now

With October 1 fast approaching, employers should:

1. Audit your job postings and offer processes. Ensure every job advertisement includes a good-faith wage range and benefits description. Make sure recruiters and hiring managers understand they must provide this information beforeany compensation discussion.

2. Review your training repayment agreements. If you require employees to sign any form of repayment agreement for training costs as a condition of employment, evaluate whether it falls within the narrow exceptions. If not, stop requiring it as of October 1.

3. Prepare your ADA accommodation notices. Develop or obtain the required written notice of ADA accommodation rights. Build distribution into your onboarding process starting October 1. For existing employees, the deadline is late January 2027, but there’s no reason not to start now.

4. Update your lactation accommodation policies. Make sure your policies reflect the new mandatory – not permissive – break-time and space requirements. Update handbook language accordingly.

5. Create your pay code guide (100+ employees). Begin developing your guide, translating it into the required languages, and posting it on your website. Coordinate with your payroll provider if applicable.

6. Train HR and management. Make sure the people responsible for hiring, onboarding, and day-to-day employment decisions understand the new obligations and timeline.

Looking Ahead

For now, the priority is October 1. Take the time to review your policies, update your processes, and get your team aligned. We’ll have more on the construction contract joint liability and wage payment provisions (effective January 1, 2027) and the service contractor employee retention requirements (effective July 1, 2027) as those dates approach. If you need help assessing your compliance posture, don’t hesitate to reach out.