Connecticut CART Act Day One: Developer Disclosure Duties and the Trade-Secret Carve-Out Went Live October 1, 2026

Connecticut CART Act Day One: Developer Disclosure Duties and the Trade-Secret Carve-Out Went Live October 1, 2026

The effective-date watch has fired: Connecticut's SB 5 (Public Act 26-15, the "CART Act," signed May 27, 2026) reached its first compliance milestone on October 1, 2026. Per DCI's employer guidance: "The first deadline is October 1, 2026, when developer information-sharing obligations and the trade-secret carve-out go live." The enrolled act carries the same date — "(Effective October 1, 2026)" for the automated employment decision technology (AEDT) developer provisions.

What is binding now vs. later:

• Live since October 1, 2026: AI developers must supply employers with all information needed for the Act's AEDT disclosures (where the tool was marketed or contracted for employment use), and the trade-secret mechanism is active — a party withholding information must notify the counterparty and state the reason. Developers may also contractually assume the employer's disclosure duties entirely, making vendor-contract negotiation the immediate compliance lever.
• October 1, 2027: the employer-facing notice obligations begin applying to newly deployed AEDTs — plain-language interaction notices and written pre-decision notices (tool purpose and trade name, categories of personal data analyzed and how, data sources, employer contact)¹.
• Enforcement architecture: "the law grants no private right of action. Only the Attorney General may bring suit and must first issue a 60-day cure notice for violations occurring before December 31, 2027."
• Discrimination backstop (Sections 13–14): using an AEDT is no shield to a discrimination claim under Connecticut's employment statutes; while bias audits are not mandated, courts and the Commission on Human Rights and Opportunities may weigh evidence of anti-bias testing — its "quality, recency, scope, and results" — as a mitigating factor.
• Pipeline: a UConn-led study of AI-related layoffs reports to the General Assembly by January 1, 2027, with findings expected to shape the next legislative round.

Enterprise takeaway: the near-term burden shift this week is on developers (disclosure outputs, trade-secret justifications), while deployers' own notice duties lag a year — but the discrimination-statute amendment applies to algorithmic decisions now, so audit documentation is the cheapest insurance available. California's parallel batch — California's AI Endgame: SB 947 "No Robo Bosses Act" Signed September 30 — Newsom's Final Signing Period Delivers a Four-Bill Workplace AI Package — went further the same week (barring sole reliance on automated systems for discipline/termination, operative July 1, 2027), and the FCRA theory against AI hiring vendors remains pending in FCRA and ICRAA Class Action Against Eightfold AI: Motion to Dismiss Under Submission Following Order Vacating Hearing.