October 1 may not seem like a big day, but for employers, today’s the day that a bunch of new employment laws become effective.
None of this should be a surprise if you’ve followed this blog; I’ve reported on all the developments over the last several months. But if this has still caught you off guard, I’ve got some highlights below and encourage clients to attend our in-person seminar later this month. This post only covers some of the assortment of laws that went into effect today and is not intended as a replacement for individualized advice we provide to clients about all applicable laws.
All Employers: Wage Transparency Gets a Major Expansion (Effective October 1, 2026)
Effective October 1, 2026, all employers must ensure their internal and public job postings list the position’s wage range and a general description of benefits. Benefits includes health insurance, retirement, fringe benefits, paid leave, and other non-wage compensation.
The new law also expands anti-retaliation protections to prohibit refusing to interview, hire, or promote, or terminating any applicant or employee for exercising their rights under this section. Notably, the bill removes the availability of punitive damages but extends the statute of limitations from a one-year window to two years after the violation.
All Employers: Employment Promissory Notes Are Effectively Banned (Effective October 1, 2026)
The new law dramatically expands the prohibition on employment promissory notes. The promissory notes require employees to repay employers if they leave before a stated period of time. They are often instituted to assist employers in recouping any training costs that may be lost if an employee leaves prematurely, and were already banned in Connecticut for large employers. But the new law expands the ban to all employers. Any employment promissory note executed on or after October 1, 2026, that requires an employee to repay the employer if the employee leaves before a stated period will be void as against public policy.
Certain exceptions remain: agreements requiring repayment of advances, payment for property sold or leased to the employee, educational personnel sabbatical leave terms, and collectively bargained programs are not affected.
All Employers: Mandatory Lactation Accommodations (Effective October 1, 2026)
Employers must now “provide reasonable break times” for employees to express breast milk or breastfeed on site, and these breaks must be in addition to the employee’s regularly scheduled breaks. Previously, the law merely allowed employees to use meal or break periods at their discretion.
Employers must also make reasonable efforts to provide a private room (not a toilet stall) that is free from intrusion and shielded from the public, situated near a refrigerator or portable cold storage device, and includes access to an electrical outlet. Anti-retaliation protections apply, and the law covers any employer with one or more employees.
All Employers: New ADA Accommodation Notice Requirement (Effective October 1, 2026)
The new law creates an entirely new notice obligation: employers must provide written notice of an employee’s right to reasonable accommodations under the ADA to (1) new employees at the commencement of employment, (2) existing employees within 120 days of October 1, 2026, and (3) any employee who notifies the employer of a disability, within 10 days of notification. Employers may comply by displaying the poster created by the Labor Commissioner in a conspicuous, accessible location.
Large Employers: Pay Stub Transparency (Effective October 1, 2026)
All employers with 100 or more employees – public and private – face a new obligation to create and publish a guide to their pay codes for overtime and commonly used pay differentials—including shift differentials, on-call pay, hazard pay, call-back pay, holiday or weekend pay, and geographical differentials. The guide must include at least 10 pay codes (if applicable), be posted on the employer’s website in English, Spanish, and the other most common languages spoken by employees, and include contact information for a designated individual who will handle disputes regarding hours and pay calculations.
Construction Employers: Prevailing Wage and Certified Payroll Enhancements (Effective October 1, 2026)
The new law adds a daily record-keeping requirement for employers on public works projects. Each employer must maintain a daily record of all mechanics, laborers, and workers at the site, including their name, trade license number, and arrival and departure times. These records must be submitted weekly to the contracting agency, and they are public records subject to inspection. Failure to file the daily records is a class C misdemeanor punishable by a fine of up to $500, imprisonment for up to three months, or both
The bill also establishes a mandatory debarment referral process for contractors or subcontractors whose cumulative settlements exceed $50,000 in back wages or $50,000 in civil penalties during a rolling three-year period.
Cannabis Employers: Industry Labor Peace Agreements (Effective October 1, 2026)
The new law updates the cannabis labor peace agreement framework, clarifying that workers at cannabis establishments, dispensary facilities, and producers may not have their wages supplemented by gratuities for minimum wage purposes. Any such employer paying less than the minimum fair wage is in violation of the law. The bill also maintains the requirement for provisional licensees to enter labor peace agreements as a condition of final license approval.
AI & Employment Law (Effective October 1, 2026)
Beginning October 1, 2026, any employer that serves written notice to the Department of Labor under the federal WARN Act must also disclose whether the layoffs are related to the employer’s use of artificial intelligence or another technological change, in the form and manner the Labor Commissioner prescribes.
As discussed in a prior post, there are also changes to the state’s anti-discrimination laws so that AI cannot be used as a defense to discrimination cases.
All Employers: Electronic Monitoring Revisions (Effective October 1, 2026)
As I covered last month, there are three main changes employers need to understand.
Notices must now include specific monitoring locations. Under the old law, employers had to tell employees the types of electronic monitoring that may occur. The new law adds a second requirement: employers must also disclose the specific locations on the employer’s premises where monitoring may occur.
That means your notice can no longer just say “we may monitor computer usage and telephone calls.” It now has to identify where that monitoring is happening. If you have cameras in the warehouse, monitoring software on workstations in a particular department, or recording equipment in the call center, those specific locations need to be called out.
Posting requirements are expanded. The old law required employers to post a notice in a conspicuous place readily available for employees to view. The new law keeps that requirement but goes further. Now, the notice must also be posted in the specific location where the monitoring occurs. So if you monitor employees in three different areas of your facility, the notice needs to be posted in each of those areas as well.
New hires must receive a plain language written statement. For any employee hired on or after October 1, 2026, employers must provide a written statement in plain language, before the employee starts work, advising which activities are prohibited and may be monitored without prior notice. This refers to the law’s existing exception that allows employers to monitor without notice when they have reasonable grounds to believe an employee is engaged in conduct that violates the law, violates the legal rights of the employer or other employees, or creates a hostile workplace environment.
All Employers: Other Laws To Consider
There are several other laws that are worth considering too. For example, Public Act 26-28 now states that employer-required security screening time is compensable. Public Act 26-12/17 now requires daily sign-in logs on public works.
And of course, effective January 1, 2027, minimum wage will go up to $17.48 per hour too.
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