Connecticut Passes AI Omnibus, Set to Enter Force This Year

The Connecticut legislature became the latest to pass AI regulation. Rather than a number of piecemeal regulations, the legislature opted to tackle multiple AI issues in one omnibus bill. The bill regulates AI and social media in a variety of ways including:

•  Regulating automated decision-making technology in employment
• Creating whistleblower protections for frontier model developers
• Regulating AI companion chatbots
• Requirements that large AI providers embed data in their content that marks it as AI-generated
• Social media protections for minors, including time limits and disclosure obligations
• Third-party AI model safety verification; and
• Required disclosures for AI-related layoffs

A recent Freshfields memo covers the new compliance obligations under the law and provides companies with practical tips:

• “Inventory AI systems across employment, consumer-facing, and subscription use cases to identify applicable provisions; engage with AI tool vendors now on the data, logic, and anti-bias testing disclosures that employment deployers will need by October 2027;
• Evaluate consumer-facing chatbots against the companion definition and minor-protection requirements effective January 2027;
• Assess readiness for C2PA-aligned provenance data if operating a generative AI system above the 1M-user threshold; monitor federal preemption developments and maintain compliance programs flexible enough to adapt; and
• Consider participating in the AI working group (first meeting by August 31, 2026) and sandbox planning processes to help shape implementation.”

The law’s provisions are phased in over the next two years, with the earliest provisions coming into force on October 1, 2026. Companies subject to the law should start assessing their compliance obligations immediately.