Connecticut and Colorado Employers Face New AI Hiring Compliance Requirements
Connecticut:
Connecticut recently enacted the “Act Concerning Online Safety”, making Connecticut one of the latest states to regulate AI in hiring. Among other things, the law requires employers using “automated employment-related decision technology” (AEDT) to provide written pre-decision notice—including, among other things, the AEDT’s purpose, trade name, the data categories of the employee or applicant that the tool will analyze or process, and how data will be assessed—before an employment-related decision is made, if such AEDT generated an output for the purpose of making or was a substantial factor in making such employment-related decision. Notice obligations are effective on October 1, 2026 but apply to tools deployed on or after October 1, 2027.
Colorado:
We previously reported on SB 26-189 in Colorado, focusing on “automated decision-making technology” and slated to go into effect on January 1, 2027. On August 11, Colorado released a proposed rulebook governing the implementation of the new law. Under the rules, any employer that deploys Covered ADMT to materially influence a “Consequential Decision” relating to employment, must comply with a detailed set of disclosure and notice obligations include with respect to adverse outcome notices, meaningful human review, and data correction rights. Comments on the proposed rulemaking are currently open through October 26, 2026. Written comments will be added to the rulemaking record.
