Connecticut Focuses On Up-Front Pay Transparency

Connecticut employers will soon need to provide pay transparency disclosures in their internal and external job postings.

New Posting Requirements

Under Public Act 26-12 (House Bill 5003), which goes into effect on Oct. 1, 2026, employers must disclose the wage or wage range for positions in internal or external job postings. Currently, when in the process of hiring a new employee, Connecticut employers are only required to provide the wage range upon an applicant’s request, prior to or at the time of an offer of compensation, or at the time of hire. The new law will require employers to be transparent about wages from the outset.

Not only will employers need to disclose wage information in their job postings, but they will also be required to include a general description of benefits.

Importantly, the new law answers an open question about the applicability of the statute to out-of-state employers and employees. It provides: “The provisions of this section shall apply to any position in which the duties of such position will be performed within the state or in which the duties for such position will be performed outside of the state but requires the employee performing such duties to report directly to a supervisor, office or other worksite located within the state.”

The statute also closes other gaps in the pay transparency timeline. If an employer has not posted a position, then the same information must be provided before any compensation discussion. For existing employees, the same information must be provided at hire, at role change, and upon request.

The new law also prohibits retaliation against applicants or employees who exercise their rights and clarifies that a private right of action must be brought within two years of the claimed violation. The new law also removes punitive damages as a category of recoverable damages.

Open Questions

The statute defines “wage range” as the range the employer “sets in good faith for a position,” which may be based on a pay scale, a previously determined range, the actual range for comparable employees, or the employer’s budgeted amount. It also defines “benefits” as “health insurance benefits, retirement benefits, fringe benefits, paid leave and any other compensation other than wages to be offered with a position.”

What this means in practice is still to come. Other states with similar pay transparency laws have taken different paths on the level of required detail, particularly for benefits descriptions and the breadth of wage ranges.

Employers should monitor for forthcoming guidance from the Connecticut Department of Labor.

Takeaways

Once the new law goes into effect, employers should plan to include wage and benefits information in job postings. When no position is posted, employers still should be prepared to provide the required information before compensation is discussed. Employers should review their hiring and posting practices now to ensure the ranges they publish and the benefits they describe are accurate, supportable, and consistently applied.