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Conn. Enacts Law Regulating AI Hiring Bots and AI Companions

The Connecticut General Assembly enacted legislation establishing requirements for automated employment decision tools and AI companion chatbots. A "companion" is generally defined under the legislation as a "natural language interface that (i) provides adaptive, human-like responses to user inputs, including, but not limited to, by exhibiting anthropomorphic features, and (ii) is able to sustain a relationship across multiple interactions."

Under the Connecticut Artificial Intelligence Responsibility and Transparency Act, deployers of automated employment-related decision technology ("AEDT") must disclose to job applicants and employees that they are interacting with the technology. Deployers must provide advance written notice describing the tool's purpose, trade name, and the types and sources of personal data used in employment decisions. The act, formally titled An Act Concerning Online Safety, requires developers to supply deployers with the information necessary to comply. Additionally, the act amended state anti-discrimination law to prohibit employers from using AEDT as a defense against discrimination claims, though they may introduce evidence of anti-bias testing.

Operators of AI companions will be required to implement reasonable measures to prevent the technology from claiming to be human and must give clear and conspicuous notice when the companion would cause a reasonable individual to believe he or she is talking to a person. Operators must implement a two-tiered escalation protocol for detecting expressions of self-harm or suicide risk, which mandates that a second detection trigger a referral to mental health services consistent with clinical best practices. The legislation also establishes protections for minors, requiring screen-time and parental controls and prohibiting chatbots that encourage self-harm, discourage users from seeking mental health assistance, or engage in sexually explicit interactions.

Violations are treated as unfair or deceptive trade practices under the Connecticut Unfair Trade Practices Act ("CUTPA"). The AI act forecloses a private right of action for the AEDT, subscription, provenance, and general AI companion provisions, each of which declares CUTPA's private-action statute inapplicable. The section governing AI companions used by minors is drafted without that bar.

The act phases into effectiveness beginning October 1, 2026.

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