Connecticut’s New AI Hiring Law Has Two Deadlines. Most Vendors Are Only Watching One.

Connecticut just became the latest US state to regulate AI in hiring, and it did something none of the states we’ve covered so far did: it split its obligations across two separate effective dates almost exactly a year apart. Public Act 26-15, the Connecticut Artificial Intelligence Responsibility and Transparency Act, or CART Act, starts enforcing its statutory framework on October 1, 2026. The part employers actually notice, the requirement to tell a candidate they’re talking to AI, doesn’t kick in until October 1, 2027. Most vendor-diligence conversations happening right now are about the second date. That’s the wrong one to be planning around first.

What actually starts October 1, 2026

The first effective date isn’t about disclosure at all. It puts the CART Act’s core definitions and enforcement structure into force: what counts as “automated employment-related decision technology” (AEDT), who the Connecticut Attorney General can go after, and a specific clarification that using an AEDT is not a legal defense against a discrimination claim. Separately, employers filing layoff notices under Connecticut’s WARN Act must now disclose whether the layoffs are connected to AI or other technological change, a disclosure requirement for the exit side of employment, not the hiring side, that takes effect on the same date. None of that requires telling a candidate anything. It requires an employer to already know, on day one, which of its tools count as AEDT and be ready to defend how they were validated if the AG asks.

The second date is the one that reads like every other state’s AI-hiring law. Starting October 1, 2027, employers that deploy an AEDT to interact directly with applicants or employees, the exact shape of a voice or chat screening tool, must disclose in plain language that the person is dealing with automated technology, unless a reasonable person would find that obvious. Where the AEDT is a substantial factor in an adverse decision, the employer also has to give a plain-language explanation of the principal reasons, the categories and sources of data used, and a path to correct inaccurate personal data.

Why the twelve-month gap is the actual story

A year is a long runway for a disclosure requirement, and that’s exactly the trap. Teams that hear “Connecticut, 2027” file it under next year’s problem and move on. But the enforcement structure, the AEDT definition, and the loss of the “the AI did it” defense all land in October 2026, over the same 12 months a TA team will be running its next full campus-hiring cycle for roles that touch Connecticut, including GCC and offshore-delivery operations that place candidates into Connecticut-based teams without a single recruiter sitting in the state. We wrote about this same jurisdictional reach when Texas’s TRAIGA took effect earlier this year: a state AI-hiring law doesn’t care where your recruiting desk sits, it cares where the role and the candidate sit. Connecticut’s AEDT definition is broad enough to catch a resume-scoring step and a voice-screening step both, and the definitions employers will need in 2027 to build a disclosure notice are the exact ones that start being enforceable in 2026.

What this means operationally, starting now

If any part of your screening pipeline evaluates candidates for Connecticut-based roles, the honest starting question isn’t “do we have a disclosure banner ready for 2027.” It’s “can we currently name, in writing, every tool in our pipeline that outputs a score, ranking, or recommendation that materially affects a hiring decision, and do we know which of those a Connecticut regulator would call an AEDT.” That inventory is the same one you’ll eventually need to build the 2027 disclosure notice, so doing it now instead of waiting costs nothing extra and removes the discrimination-defense gap a year early.

The contrarian take

Vendors and TA teams keep treating “the disclosure date” as the compliance deadline for every AI-hiring law, because disclosure is the requirement that’s visible to a candidate and easy to demo in a sales deck. Connecticut’s structure shows why that instinct is backwards. The requirement that actually changes an employer’s legal exposure, losing the ability to blame the tool for a discriminatory outcome, arrives a full year before the requirement that changes what a candidate sees on screen. If your compliance checklist for a new state law only has one date on it, you’re tracking the part of the law that’s easiest to notice, not the part that changes your risk first.

Talk to us if you want a second read on whether your current screening stack would already count as an AEDT under Connecticut’s definition, before your 2026 campus cycle touches a Connecticut role.