The following article was first published in Shipman & Goodwin‘s Employment Law Letter. It is reposted here with permission.
Connecticut’s AI Responsibility and Transparency Act takes effect on Oct. 1, 2026.
If your company uses artificial intelligence in any aspect of employment decision-making, the time to prepare is now.
We wrote about the CAIA earlier this year, identifying the law’s key provisions and what they mean for employers.
This post builds on that earlier discussion with a practical focus: what employers should do now to be ready by Oct. 1.
The CAIA regulates the use of “high-risk” artificial intelligence systems, meaning those used to make or substantially inform consequential decisions about people.
For employers, it applies to AI tools used in hiring, promotion, discipline, termination, and other significant employment decisions.
The law draws a distinction between developers (the companies that build AI systems) and deployers (the companies that use them).
Most employers fall into the deployer category. If you use any AI-powered tool that makes or substantially informs employment decisions, you may be covered as a deployer.
Common examples include resume-screening software, automated candidate interview tools, and performance evaluation platforms.
If you are a deployer of a high-risk AI system, the CAIA requires you to:
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