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Connecticut’s Omnibus Workforce Bill: What Employers Need to Know 

Employment Law Letter | Blog

By: Sarah N. Niemiroski

May 04, 2026

Lawyers

 Sarah N. Niemiroski
Sarah N. Niemiroski

Associate

860.251.5070

sniemiroski@goodwin.com
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    Connecticut’s Omnibus Workforce Bill: What Employers Need to Know  on Employment Law Letter

About HB 5003

As the 2026 legislative session comes to a close, the Connecticut General Assembly has passed a sweeping bill impacting many aspects of the employer-employee relationship for private and public sectors alike.  From wage transparency and training repayment agreements to lactation accommodations, an “Act Concerning Workforce Development and Working Conditions in Connecticut” – or House Bill 5003 – represents one of the most ambitious packages of workforce legislation that Connecticut has seen in recent years.  Below is a summary of the key changes that will affect most employers’ operations.  

All Employers: Wage Transparency Gets a Major Expansion (Effective October 1, 2026)

Connecticut’s existing wage transparency law is getting a significant overhaul. Previously, Connecticut only required employers to provide the wage range upon request of an applicant or at the time an offer was made. Connecticut will be joining California, Colorado, Hawaii, Illinois, Maryland ,Massachusetts, Minnesota, Nevada, New Jersey, New York, Rhode Island, Vermont, and Washington (plus D.C.), in requiring employers to post the wage range in job advertisements.  Effective October 1, 2026, all employers must ensure their internal and public job postings list the position’s wage range and a general description of benefits.  Benefits includes health insurance, retirement, fringe benefits, paid leave, and other non-wage compensation.  

The bill also expands anti-retaliation protections to prohibit refusing to interview, hire, or promote, or terminating any applicant or employee for exercising their rights under this section. Notably, the bill removes the availability of punitive damages but extends the statute of limitations from a one-year window to two years after the violation.

Key Takeaways:

  • Update your job posting templates to include wage ranges and benefits descriptions. 
  • Train recruiters not to discuss compensation before providing the required disclosures. 
  • Review your internal processes for position changes to ensure timely wage range communication.

All Employers: Employment Promissory Notes Are Effectively Banned (Effective October 1, 2026)

Employers should take note: the bill dramatically expands the prohibition on employment promissory notes.  The promissory notes require employees to repay employers if they leave before a stated period of time.  They are often instituted to assist employers in recouping any training costs that may be lost if an employee leaves prematurely, and were already banned in Connecticut for large employers.  But the amendment will expand the ban to all employers.  Any employment promissory note executed on or after October 1, 2026, that requires an employee to repay the employer if the employee leaves before a stated period will be void as against public policy. 

Certain exceptions remain: agreements requiring repayment of advances, payment for property sold or leased to the employee, educational personnel sabbatical leave terms, and collectively bargained programs are not affected. 

Key Takeaways:

  • Audit all existing onboarding documents, training agreements, and retention bonus structures. 
  • If your organization currently uses repayment obligations tied to early departure, consult counsel before October 1 to determine whether your agreements fall within the narrow exceptions.

All Employers: Mandatory Lactation Accommodations (Effective October 1, 2026)

The existing lactation accommodation law is being upgraded from largely permissive language to affirmative employer mandates. Under the revised statute, employers “shall provide reasonable break times” for employees to express breast milk or breastfeed on site, and these breaks must be in addition to the employee’s regularly scheduled breaks. Previously, the law merely allowed employees to use meal or break periods at their discretion.

Employers must also make reasonable efforts to provide a private room (not a toilet stall) that is free from intrusion and shielded from the public, situated near a refrigerator or portable cold storage device, and includes access to an electrical outlet.  Anti-retaliation protections apply, and the law covers any employer with one or more employees.

Key Takeaways:

  • Evaluate your current lactation spaces. Ensure they meet all three requirements—privacy, refrigeration access, and an electrical outlet. 
  • Update your employee handbook to reflect the mandatory (not optional) nature of these breaks.

All Employers: New ADA Accommodation Notice Requirement (Effective October 1, 2026)

The bill creates an entirely new notice obligation: employers must provide written notice of an employee’s right to reasonable accommodations under the ADA to (1) new employees at the commencement of employment, (2) existing employees within 120 days of October 1, 2026, and (3) any employee who notifies the employer of a disability, within 10 days of notification.  Employers may comply by displaying the poster created by the Labor Commissioner in a conspicuous, accessible location.

Key Takeaways:

  • Watch for the Labor Commissioner’s poster and incorporate the notice into your onboarding process. Calendar the 120-day deadline for notifying existing employees (January 29, 2027).

Large Employers: Pay Stub Transparency (Effective October 1, 2026)

All employers with 100 or more employees – public and private – face a new obligation to create and publish a guide to their pay codes for overtime and commonly used pay differentials—including shift differentials, on-call pay, hazard pay, call-back pay, holiday or weekend pay, and geographical 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 employees, and include contact information for a designated individual who will handle disputes regarding hours and pay calculations.

Employers must provide the website address to the guide upon hire and include it on each pay record furnished to employees.  Employers using third-party payroll services that provide an adequate guide are deemed in compliance.  Notably, no employer is required to establish a website or new pay codes solely to comply with this section.

Key Takeaways:

  • Assess whether your existing payroll documentation meets the new transparency standard.
  • Coordinate with payroll providers to determine whether their tools satisfy the requirement. 

Education & Healthcare Employers: Enhanced Workers’ Compensation for Assault Victims (Effective October 1, 2026)

The bill adds new protections for healthcare workers, board of education members (including the State Board of Education, the Board of Regents for Higher Education, and the Board of Trustees for UCONN), and their employees who are physically or negligently assaulted while acting within the scope of their duties. These individuals will be entitled to workers’ compensation at 100% of average weekly earnings—uncapped by the usual maximum weekly benefit rate—plus reimbursement for medical expenses and lost wages due to court appearances related to the assault.  Importantly, the time absent due to assault-related injury or court appearances cannot be charged against sick leave, vacation, or personal leave. 

Key Takeaways:

  • Healthcare facilities and educational institutions should review their workers’ compensation coverage and workplace violence policies to align with these enhanced obligations.

Public Education Employers: Teacher Termination Process Change (Effective July 1, 2026)

Under the bill, the standard of review for all reasons for termination of a tenured teacher shall be the same standard applied in other disciplinary actions under the terms of such teacher’s collective bargaining agreement.  Additionally, hearings for tenured teachers will now be conducted exclusively before an impartial hearing officer (selected by the teacher and superintendent or through the American Arbitration Association’s expedited process), and the hearing officer’s disposition will be binding on the parties. An additional alert will follow directly related to these changes.

Key Takeaways:

  • School districts should prepare for a more formal and potentially more expensive termination process.
  • Legal counsel should be engaged early in any contemplated termination.

Most Employers: Successor Employer Obligations for Service Contracts and Property Transfers (Effective July 1, 2027)

In what amounts to a displaced worker protection act, the bill creates a new framework requiring successor employers on service contracts—and in certain property sales or transfers—to retain the prior contractor’s workforce for at least 90 days.  For the purposes of this provision, employer means any person employing two or more employees, including municipal or local governments.  The term, however, excludes the federal government, the state, and the Connecticut Airport Authority.  The bill requires awarding authorities to provide 15 days’ advance notice of contract termination or property transfer to affected employees and their bargaining representatives.  Successor employers must hand-deliver written offers of employment in the employee’s native language at least five days before the prior contract ends. 

During the 90-day transition, successor employers may not discharge retained employees without “just cause” determined solely by individual performance or conduct.   After the period ends, a satisfactory performance evaluation entitles the employee to continued employment. Penalties for violations range from $500 to $1,000 per employee per day for failure to retain, and $50 to $200 per employee per day for notice violations. 

Key Takeaways: Employers that regularly bid on service contracts or acquire properties with existing service workforces should build these retention and notice obligations into their transition planning and contract pricing. The penalties are significant and enforceable through the Labor Commissioner or Superior Court.

Construction Employers:  Contractor Joint and Several Liability for Wage Theft (Effective January 1, 2027)

General contractors entering construction contracts on or after January 1, 2027, will be jointly and severally liable for unpaid wages owed to employees of their subcontractors.  Employees may bring civil actions against the subcontractor, the contractor, or both, provided they give the contractor at least 30 days’ notice before filing suit.  Contract provisions that waive or release this liability are unenforceable. 

Key Takeaways: Construction industry employers should revisit subcontractor agreements, strengthen due diligence on subcontractor payroll compliance, and ensure indemnification clauses account for this new joint liability exposure.

Construction Employers: Prevailing Wage and Certified Payroll Enhancements (Effective October 1, 2026)

The bill adds a daily record-keeping requirement for employers on public works projects. Each employer must maintain a daily record of all mechanics, laborers, and workers at the site, including their name, trade license number, and arrival and departure times.  These records must be submitted weekly to the contracting agency, and they are public records subject to inspection. Failure to file the daily records is a class C misdemeanor punishable by a fine of up to $500, imprisonment for up to three months, or both

The bill also establishes a mandatory debarment referral process for contractors or subcontractors whose cumulative settlements exceed $50,000 in back wages or $50,000 in civil penalties during a rolling three-year period. 

Key Takeaways: Public works contractors should implement daily sign-in/sign-out procedures and electronic record-keeping systems to satisfy the new daily reporting obligations.

Cannabis Employers: Industry Labor Peace Agreements (Effective October 1, 2026)

The bill updates the cannabis labor peace agreement framework, clarifying that workers at cannabis establishments, dispensary facilities, and producers may not have their wages supplemented by gratuities for minimum wage purposes.  Any such employer paying less than the minimum fair wage is in violation of the law. The bill also maintains the requirement for provisional licensees to enter labor peace agreements as a condition of final license approval.

Other Notable Provisions

Several additional sections warrant mentioning:

The bill establishes a task force to study support for persons with disabilities earning sub-minimum wages under Section 14(c) of the Fair Labor Standards Act.  It creates a deferred retirement option plan authorization for municipalities outside the Municipal Employees’ Retirement Fund.  A new virtual monitoring framework governs surveillance of direct care workers, requiring confidentiality agreements and access protections when disciplinary evidence is derived from monitoring.  The bill provides for first responder tuition waivers and mortgage assistance programs, with eligibility requirements to be established by the relevant councils and commissions.  And it creates an internship quality standards and training course program, with a potential future tax credit expansion for employers who earn a credential for offering high-quality internships.

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