NEW LABOR RELATED LAWS STARTING OCT 1

Prohibition on Promissory Notes Expands to All Employers

Effective October 1, 2026

The ban on promissory notes as a condition of employment now applies to employers of any size, eliminating the previous exemption for employers with fewer than 26 employees. These notes require an employee to pay the employer if the employee leaves before a specified period. Any promissory note executed on or after October 1, 2026, will be void.

Minimum Wage at Cannabis Establishments

Effective October 1, 2026

The Act prohibits cannabis establishments, dispensaries, or producers from counting tips or gratuities toward minimum wage. Any employer that agrees to pay less than minimum wage will be in violation of the law.

New Tenured Teacher Termination Procedures

Effective July 1, 2026

The Act now requires that the standard of review for the grounds on which a tenured teacher may be terminated will be the same standard applied in other disciplinary actions under the terms of such teacher’s collective bargaining agreement. Typically, this would be a “just cause” standard.  It establishes that impartial hearing officers must hear dismissal cases, replacing  board hearings. The hearing officer’s decision is now binding, subject to judicial review. Boards of education, like teachers, may seek judicial review.

Disability Accommodation Disclosures

Effective October 1, 2026

The new statute requires employers to notify employees of their rights under the Americans with Disabilities Act (ADA). An employer must provide all new employees with written notice of their right to request a reasonable workplace accommodation when they begin their employment. Current employees must be notified within 120 days of October 1, 2026, and new employees upon hire.  Thereafter, if an employee informs the employer of a disability, the employer must provide notice of the employee’s rights to reasonable accommodation within 10 days. An employer may satisfy the notice requirement by displaying a poster created by the Labor Commissioner in a conspicuous location in the workplace.

Increase in Lactation Break Periods

Effective October 1, 2026

The Act expands on the circumstances under which employees are free to breastfeed or express breast milk at work.  Employers must now provide “reasonable break times” to express breast milk in addition to regularly scheduled break periods already required under existing law. Employers must continue to ensure access to space where the employee can express breast milk in private, provided that it is shielded from the public and free from intrusion, situated near a refrigerator, and has access to an outlet.

Enhanced Pay Code Transparency

Effective October 1, 2026

The Act expands wage-transparency obligations to employers with 100 or more employees. Covered employers must create a guide of at least 10 pay codes for overtime and commonly used pay differentials, such as shift differentials, on‑call pay, hazard pay, call‑back pay, holiday or weekend pay, and geographic pay differentials. The employer must post these guides on their website in English, Spanish, and any other language commonly spoken by employees. The employer must also provide new hires with the guide’s web address (if the employer maintains such a website) and include that address on each record of hours and wages provided to an employee. Compliance with this requirement can be satisfied by using third-party payroll services that supply a pay code guide.

New Prevailing Wage Recordkeeping Requirements

Effective October 1, 2026

The Act now requires employers on Connecticut public works projects to prepare daily records for each person working on a job site as a mechanic, laborer, or worker. Each daily record must include:

• The project name and location

• The current date

• The employee’s printed name and signature, and (if applicable) the employee’s trade license number

• The employee’s arrival and departure time at the job site.  

The employer must keep these records and submit them weekly to the contracting agency or Department of Economic and Community Development. Failing to file records will result in a Class C misdemeanor. The statute expressly clarifies that these records are public records under the Freedom of Information Act.

The Act also updates how prevailing wages are set. When determining the prevailing wage and required benefit payments for a public works contract in a particular town, the Labor Commissioner must now consider the journeyman rate, in addition to other factors.

Contractor Liability for Wage Theft

Effective January 1, 2027

General contractors are now jointly and severally liable for the subcontractor’s failure to pay its employees’ wages.  See Harris Beach Murtha’s previous alert titled Conn. Enacts Law Expanding Upstream Liability for Unpaid Construction Wagesfor more information.

Harris Beach Murtha’s Labor and Employment Practice Group will continue to monitor these issues and report on new developments. If you have questions or need assistance with this or other labor matters, please reach out to attorney Salvatore G. Gangemi at (203) 653-5436 and sgangemi@harrisbeachmurtha.com, or the Harris Beach Murtha attorney with whom you most frequently work.

This alert is not a substitute for advice of counsel on specific legal issues.