Connecticut’s Public Act 26-12 Brings Major Workplace Compliance Changes: What Employers Need to Know

Connecticut employers have a major new compliance law to prepare for, and this one is not a tiny “update your poster and move on” situation. Public Act No. 26-12, signed by the governor on May 11, 2026, is a sweeping omnibus labor and employment law that changes multiple areas of Connecticut workplace compliance. Littler describes it as one of the most comprehensive overhauls of Connecticut workplace law in recent years.

The Act is broad. It touches pay transparency, wage statements, construction wage liability, service contract workers, healthcare employees, workers’ compensation, ADA notices, and lactation accommodations. So yes, Connecticut employers may need more than one cup of coffee for this one.

The Big Picture

Public Act 26-12 is more than 120 pages long and combines provisions from numerous individual bills introduced during the 2026 legislative session. While not every section applies to every employer, the law creates new obligations across several industries and employer types, including private employers, construction contractors, healthcare employers, service contractors, and employers with Connecticut-based supervisors, offices, or worksites.

The best way to approach this law is not to ask, “Does this whole thing apply to us?” Instead, employers should ask, “Which pieces apply to our workforce, our industry, our job postings, our payroll practices, and our contracts?”

That is where the real compliance work begins.

1. Pay Transparency Expands to All Employers

One of the most significant changes is Connecticut’s expanded job posting requirement.

Effective October 1, 2026, all employers, regardless of size, must include the position’s wage or wage range and a general description of benefits in both public and internal job postings. Benefits are defined broadly and include health insurance, retirement benefits, fringe benefits, paid leave, and other compensation offered with the position.

The Act also changes the definition of “wage range.” Instead of using a range the employer “anticipates relying on,” the law now refers to a range the employer “sets in good faith.” That wording matters because it suggests employers should be prepared to support the posted range with a reasonable, legitimate basis.

This requirement also reaches beyond traditional Connecticut job postings. Littler notes that the amended statute applies not only to jobs performed in Connecticut, but also to out-of-state positions that report to a Connecticut-based supervisor, office, or worksite.

That means employers should review remote and hybrid job postings carefully. A job may not be physically located in Connecticut, but it could still be pulled into the law if the reporting structure connects back to Connecticut.

2. Employment Promissory Note Restrictions Will Apply to All Employers

Connecticut already restricted certain employment promissory notes, including agreements requiring employees to repay amounts advanced for training, sign-on bonuses, or relocation expenses if they leave before working for a specified period. Historically, employers with 25 or fewer employees were exempt.

Beginning October 1, 2026, that small-employer exemption goes away. The restriction will apply to all employers, regardless of size.

This does not mean every repayment agreement is prohibited. Littler notes that the law does not prohibit voluntary agreements for repayment of amounts advanced by the employer.

Still, employers should review offer letters, training repayment agreements, sign-on bonus agreements, relocation agreements, and separation-related clawback language. Any provision that functions like a “stay or repay” arrangement should get a legal review before October 1.

3. Larger Employers Must Create a Pay Code Guide

Effective October 1, 2026, Connecticut employers with at least 100 employees must create a plain-language guide explaining pay codes used for overtime and commonly used pay differentials. Examples include shift differentials, on-call pay, hazard pay, callback pay, holiday or weekend pay, and geographic pay differentials.

If applicable, the guide must include at least 10 pay codes and must be updated when a new overtime or pay differential code is added. Employers must post the guide on their website in English, Spanish, and other commonly spoken languages of the workforce. The guide must also identify who handles employee questions or disputes about timekeeping and pay calculations.

Employees must receive access to the guide at hire, and employers must include a link on each record of hours worked provided to employees. Employers using a third-party payroll provider may be compliant if the provider supplies a guide that meets the statutory requirements.

This is one of those requirements that sounds simple until payroll, HRIS, legal, and communications all have to agree on what a “plain language” explanation looks like. Translation: start early.

4. Construction Contractors Face New Wage Liability

Construction employers should pay close attention to one of the Act’s biggest industry-specific changes.

For contracts entered into on or after January 1, 2027, general contractors may be jointly and severally liable for unpaid wages owed by subcontractors on construction, renovation, or rehabilitation projects in Connecticut. Before bringing a claim against the general contractor, the employee generally must provide 30 days’ notice describing the alleged violation, unless certain prior notice conditions apply.

General contractors may include subcontract language allowing unpaid wages to be satisfied from contract retainage. However, Littler notes that such language does not eliminate an employee’s right to bring a claim or waive the general contractor’s liability.

For general contractors, this is a major contract-management issue. It is no longer enough to assume the subcontractor is handling payroll correctly. GCs should consider stronger subcontractor vetting, payroll certification requirements, audit rights, indemnification language, retainage provisions, and procedures for responding to wage complaints.

5. Prevailing Wage Recordkeeping Gets More Detailed

Effective October 1, 2026, employers working on projects subject to Connecticut prevailing wage requirements must keep daily attendance records for mechanics, laborers, and other workers on covered job sites. These records must include the project name and location, date, each worker’s name, trade license number if applicable, and each worker’s arrival and departure times. Employers must submit the records weekly to the contracting agency.

Those records will be public records under the Freedom of Information Act, meaning they may be available for inspection or copying. Employers that fail to maintain and submit the records may face fines, imprisonment, or both.

Employers on public works projects should review their timekeeping process now. If daily attendance is currently tracked informally, this is the moment to tighten the system.

6. Service Contract Worker Retention Rules Are Coming

Beginning July 1, 2027, successor employers taking over certain service contracts at covered locations must retain covered service contract employees for at least 90 days. This may apply when an entity takes over a covered service contract, contracts out covered services, or receives property through a sale or transfer.

The law applies to employers with two or more employees operating in certain settings, including higher education facilities, large multifamily residential buildings, commercial buildings over 75,000 square feet, cultural centers, banks, shopping malls, warehouses, distribution centers, airports, and train stations.

The law includes notice requirements, written offer requirements, restrictions on termination during the 90-day retention period absent just cause, seniority rules when fewer workers are needed, preferential hiring list obligations, and post-retention performance evaluation requirements.

Employers involved in janitorial, security, maintenance, building services, warehouse, distribution, or similar service contracts should build this into contract transitions well before 2027. Waiting until the old contractor is walking out and the new contractor is walking in is how compliance gets spicy.

7. Healthcare and Education Workers Receive Expanded Workers’ Compensation Benefits After Assaults

The Act expands workers’ compensation protections for certain healthcare providers, teachers, and related employees who are unable to work because of a physical or negligent assault while performing their duties.

Covered employees may be entitled to benefits equal to 100% of their average weekly wage, without a cap, during periods of partial or total incapacity due to the assault. The Act also covers reasonably incurred medical and related expenses and lost wages tied to court appearances related to the assault. These absences cannot be charged against the employee’s PTO.

The covered healthcare definition is broad and includes employees and volunteers of certain healthcare facilities or institutions who have direct patient care or patient/family contact responsibilities. Covered education employees are also defined broadly.

One important practical issue: the statute does not define “physical or negligent assault,” which may create uncertainty about what situations trigger the enhanced benefits.

Healthcare and education employers should review workers’ compensation procedures, incident reporting, safety policies, PTO coding practices, and supervisor training.

8. ADA Notice Requirements Are Added

Effective October 1, 2026, the Connecticut Department of Labor must post English and Spanish information about the federal Americans with Disabilities Act on its website, including the definition of disability and reasonable accommodation obligations. Employers will be able to download the notice for workplace posting.

Employers must provide written notice of the right to reasonable accommodation to existing employees within 120 days of October 1, 2026, which makes the deadline January 29, 2027. After that, employers must provide the notice to new employees upon hire and within 10 days after an employee notifies the employer of a disability.

The trigger is important. As written, the law appears to require notice when an employee advises the employer of a disability, even if the employee has not requested an accommodation. Littler notes there may be future guidance on whether the obligation is triggered when a disability is readily observable but not communicated by the employee.

Employers should prepare a process for distributing the notice and documenting delivery. Managers should also be trained to alert HR when an employee mentions a disability, medical condition, or limitation that could trigger the notice requirement.

9. Lactation Accommodation Rights Expand

Connecticut previously required employers to make reasonable efforts to provide a private, sanitary location for employees to breastfeed or express milk during meal or break periods.

The new law expands that requirement by requiring employers to provide reasonable break times to breastfeed or express milk, not limited only to regular meal or break periods.

Employers should review lactation accommodation policies, break practices, scheduling expectations, and available private spaces. The key change is flexibility. Employers should not limit lactation breaks only to existing meal or rest periods if additional reasonable break time is needed.

What Employers Should Do Now

Connecticut employers should take a practical, staged approach.

First, identify which sections apply to your organization. A hospital, construction contractor, cannabis establishment, office building service contractor, and general private employer may each have very different obligations under the same Act.

Second, update job posting templates before October 1, 2026 to include good-faith wage ranges and benefits descriptions for both internal and external postings.

Third, review payroll and wage documents. Larger employers should begin developing the required pay code guide, including translations and website posting logistics.

Fourth, review repayment agreements and clawback provisions. Small employers that were previously exempt from Connecticut’s employment promissory note restriction should pay special attention.

Fifth, construction employers should update subcontract terms, wage compliance controls, daily attendance recordkeeping, and prevailing wage processes.

Sixth, healthcare and education employers should review workers’ compensation, assault response, PTO coding, incident reporting, and employee safety procedures.

Finally, prepare ADA and lactation accommodation updates. Notices, manager training, accommodation processes, and break policies should all be reviewed before the relevant effective dates.

Bottom Line

Public Act 26-12 is a major Connecticut employment law development. It is not one policy update. It is a multi-department compliance project.

The biggest employer takeaways are:

• Connecticut pay transparency expands to all employers on October 1, 2026.
• Employers with 100 or more employees must create a plain-language pay code guide.
• Construction general contractors may face liability for subcontractor wage violations on covered contracts beginning January 1, 2027.
• Prevailing wage projects will require detailed daily attendance records.
• Certain service contract successor employers must retain covered workers for 90 days beginning July 1, 2027.
• Healthcare and education employers face expanded workers’ compensation obligations for covered workplace assaults.
• Employers must prepare new ADA notice procedures and expanded lactation accommodation practices.

Connecticut employers should start now by mapping the law to their specific workforce and operations. This is one of those compliance changes where early planning is not just helpful. It is the whole game.