Connecticut Expands Employer Requirements Across Pay Transparency, Accommodations, Overtime Pay Guides, and More

The Bottom Line

• Connecticut’s new workforce law expands employer obligations in several areas, including pay transparency, employment promissory notes, reasonable accommodation notices, overtime pay code guides, and lactation accommodations.
• Before the October 1, 2026 effective date, employers should review and update their agreements, job postings, notices, and internal policies to comply with these new requirements.

Connecticut has passed a new law impacting numerous employer compliance obligations. Effective October 1, 2026 the Act Concerning Workforce Development and Working Conditions in the State (House Bill 5003) introduces expanded requirements related to pay transparency, employment promissory notes, reasonable accommodations notices, overtime pay code guides, and lactation accommodations.  Employers will accordingly need to update their agreements, job postings, notices, and internal policies and procedures.

Pay Transparency

All job postings will now have to include the wages or wage range and a general description of the benefits associated with such position. Employers must also provide this information when an employee is hired, changes positions, or first requests such information. These requirements apply to positions in which the employee works in Connecticut or reports to a supervisor, office, or other worksite located in Connecticut.

Employment Promissory Note / Repayment Agreements

No employer, regardless of its size, may require employees as a condition of employment to execute an agreement which requires them to pay the employer if they leave before a specified period. This includes reimbursement for training previously provided to the employee. Previously, this ban only applied to employers with at least 26 employees.

The previous exceptions to this prohibition remain in effect, which include agreements:

1. requiring an employee to repay a salary advance,
2. requiring an employee to pay for any property it sold or leased to the employee,
3. requiring educational personnel to comply with any terms or conditions of sabbatical leaves granted by their employers, or
4. entered into as part of a program agreed to by the employer and its employees’ collective bargaining representative.

Reasonable Accommodations Notice

Employers will have to provide all new employees with a written notice of their right to reasonable accommodations in the workplace for a qualifying disability. The notice must be provided within 10 days of an employee notifying the employer of a disability. Employers will also have to provide this notice to existing employees by January 29, 2027. 

Employers may comply with this requirement by displaying a poster created by the Labor Commissioner in a conspicuous place at the employer’s place of business. The Labor Commissioner is expected to publish the poster by the law’s October 1, 2026 effective date.

Overtime Pay Code Guide

Employers with 100 or more employees will have to create a written overtime pay code guide explaining overtime requirements and commonly used pay differentials (which may include shift differentials, on-call pay, hazard pay, call-back pay, holiday or weekend pay or geographic pay differentials).

The guide must include:

• at least 10 pay codes, if applicable;
• be posted on the employer’s website in English, Spanish, and the other most common languages spoken by its employees; and
• include contact information of the designated individual who will handle employee pay disputes.

However, an employer is not required to create a website if it does not have one. Employers must update the guide each time a new pay code is created.

Employers must provide the website address to employees upon hire and with each record of hours worked given to the employee. An employer may comply with this requirement by providing upon hire a written copy of the guide in English and the employee’s primary language.

Lactation Accommodations

Connecticut employers were already required to provide lactation breaks under the federal PUMP for Nursing Mothers Act and Pregnant Workers Fairness Act. With the new law, they will also be required under state law to provide reasonable break times for employees to express breast milk in addition to those employees’ other scheduled breaks.

Employers will have to make reasonable efforts to provide a room or other location near the work area, other than a toilet stall, where the employee can privately express milk. Such room or location must:

• be free from intrusion and shielded from the public;
• include or be situated near a refrigerator or employee-provided cold storage device for storing breast milk; and
• include access to an electrical outlet.

Next Steps for Employers

Before the October 1, 2026 effective date, Connecticut employers should:

• Update job postings to adhere to new pay transparency obligations;
• Review and revise agreements to ensure no prohibited repayment plans are in effect;
• Develop overtime pay code guides and update their website and onboarding materials to include the guide;
• Implement required reasonable accommodations notice; and
• Confirm lactation break policies meet the new law’s standards.