For information purposes only. Employers should consider seeking the assistance of experienced employment law attorneys before implementing policy changes.

Connecticut Governor Ned Lamont approved H.B. 5003 imposing a new requirement concerning employer transparency about pay codes used in pay statements and modifying various other state employment law provisions.

For a summary of all the workforce provisions contained in H.R. 5003, see the analysis provided by the Connecticut state legislature.

Below are some of the provisions of significant note, all of which are effective October 1, 2026.

Employee guides concerning pay code definitions

Employers with 100 or more employees are required to maintain and publish guides for their employees explaining pay codes, overtime codes and wage (e.g., shift) differentials appearing in employee pay statements.

These guides must be updated whenever a new pay code is added for pay differentials and be posted on the employer's website in English, Spanish and any other common languages spoken by their employees.

Employment promissory notes

The legislation expands Connecticut's prohibition on employment-promissory notes to all employers, regardless of workforce size.

An employment promissory note is broadly defined as any agreement or instrument that requires an employee to pay money to an employer if the employee separates from employment before a specified period, including agreements characterized as training repayment obligations. Under prior law, this prohibition applied only to employers with 26 or more employees. Effective October 1, 2026, all employers are prohibited from requiring an employee or prospective employee to execute an employment promissory note as a condition of employment.

Any employment promissory note executed as a condition of employment on or after October 1, 2026, is void and unenforceable, although the invalidity of the promissory note does not affect the enforceability of other provisions contained in the employment agreement.

Wage transparency and pay equity

The legislation significantly expands Connecticut's pay transparency requirements.

Employers must now include the wage or wage range for a position, along with a general description of available benefits, in all public and internal job postings. For this purpose, "benefits" is broadly defined to include health insurance, retirement plans, fringe benefits, paid leave and any other form of compensation offered in connection with the position, other than wages.

The legislation also accelerates the timing of required wage and benefit disclosures to applicants. Under current law, employers generally must provide wage range information before or at the time a compensation offer is made. Going forward, employers must disclose wage and benefit information either upon an applicant's request or before any discussion of compensation occurs, whichever comes first. The law defines a "wage range" as a good-faith range of compensation that an employer reasonably expects to rely upon when setting pay for a position. The range may be based on factors such as an established pay scale, a previously determined compensation range for the role, the pay of employees in comparable positions or the employer's budgeted amount for the position. While this definition provides employers with flexibility in establishing compensation ranges, it requires those ranges to be disclosed earlier in the hiring process.

Finally, the legislation further clarifies its scope, applying to positions performed in Connecticut as well as positions performed outside the state when the employee reports directly to a Connecticut-based supervisor, office or other worksite.

Lactation breaks

The legislation enhances workplace protections for breastfeeding employees by requiring employers to provide reasonable break time for an employee to express breast milk or breastfeed during the workday, in addition to any regularly scheduled meal or rest breaks.

This marks a significant change from prior law, which permitted employees to express milk or breastfeed only during existing meal or break periods. Under the new requirement, employers must provide additional reasonable break time as needed to accommodate breastfeeding employees.

The legislation does not modify Connecticut's existing accommodation requirements. Employers must continue to provide a private location in close proximity to the employee's work area, other than a restroom, that includes access to refrigeration and an electrical outlet for expressing and storing breast milk.

Ernst & Young LLP insights

Connecticut's legislation will require many employers to revisit long-standing employment, compensation and payroll practices before the various effective dates take effect. The changes extend beyond traditional wage-and-hour compliance and affect recruiting processes, job posting content, employee communications, onboarding practices and workplace accommodation policies.

Given the breadth of the new requirements and the potential for employee claims and enforcement actions, employers should consider working closely with experienced employment counsel to evaluate existing policies, employment agreements and hiring procedures. Legal review may be particularly important for multistate employers that recruit employees across jurisdictions and will need to determine whether Connecticut's requirements apply to remote positions reporting to Connecticut-based supervisors or worksites.