Connecticut’s AI Law Takes Effect October 1, Adding Consumer and Worker Protections
Subscription consent and content-origin requirements begin first. Anonymous reporting systems, companion safeguards and workplace notices follow on separate deadlines.
Connecticut’s CART Act phases in new requirements for AI businesses, with consumer-facing obligations starting before most of the law’s broader rules. From October 1, 2026, paid AI subscriptions must disclose service restrictions and obtain written acceptance, while generative-AI providers with more than one million monthly users must add tamper-resistant provenance data to content they create or materially alter. Companion, employment, and frontier-developer rules follow in 2027 and 2028, giving companies staggered deadlines to plan for.
01
Subscription disclosures must cover feature limits, access termination, and changes to restrictions at renewal—not only price and billing.
02
Frontier developers with more than $500 million in prior-year gross revenue must establish anonymous channels for reports of potentially catastrophic risks by January 1, 2027.
03
Employment notices identifying automated decision tools are due before covered use begins October 1, 2027; related protections run through Connecticut’s anti-discrimination framework.
Connecticut’s new AI law takes effect October 1, 2026, bringing subscription-renewal requirements and protections against retaliation for frontier-developer employees who report threats to public health or safety. Its chatbot safeguards arrive later.
SB5 established the Connecticut Artificial Intelligence Responsibility and Transparency Act, or CART Act. The Connecticut Attorney General’s consumer advisory identifies it as Public Act 26-15. Compliance dates vary across the law, with most business obligations beginning in 2027.
Subscription consent reaches beyond the price
Starting October 1, businesses offering paid AI subscriptions to Connecticut consumers must provide written terms and obtain written acceptance before sign-up or renewal. Sidley Austin’s legal breakdown explains that the notice must cover restrictions on the service, not just billing.
Required disclosures
Restrictions providers may impose, including those triggered by consumer conduct.
Whether providers can end access or reduce the quantity or quality of AI features.
At renewal, any new or modified limitations compared with the preceding term.
Generated content needs an origin record
Another October 1 obligation covers generative-AI providers with more than one million monthly users. They must include consumer-accessible provenance data—information capable of verifying origin or authenticity—in content their systems create or materially alter. Providers must use commercially and technically reasonable methods to make that data difficult to tamper with.
Companion rules target the relationship
Covered companions give adaptive, human-like responses and can sustain relationships across interactions. They must identify themselves as AI when that is not obvious, detect expressions of suicide, self-harm or imminent violence, and respond with mental-health resources.
Extra restrictions apply when operators know, or have reason to believe, a user is under 18. They prohibit romantic or sexually explicit interactions and certain techniques that prolong engagement. But the companion rules do not require age verification; businesses have a safe harbor if they reasonably determine a user is an adult.
Worker protections follow different routes
The anonymous reporting requirement applies to frontier developers with more than $500 million in gross revenue in the previous year. Those channels address potentially catastrophic AI risks. Separately, employment-technology notices must name the tool being used, and the law codifies prohibitions on discriminatory use.
The Attorney General can enforce several consumer-protection provisions, including companion requirements. The CART Act does not itself create a private right of action; its employment protections operate through the state’s anti-discrimination framework.
Sources
portal.ct.govRights and Requirements Related to New and Updated Privacy Laws
dailycampus.comNew AI regulation law goes into effect Oct. 1
datamatters.sidley.comTrending Issues in State AI Regulation as Seen Through Connecticut’s Omnibus AI Law (SB5) | Data Matters Privacy Blog
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