Connecticut Public Act No. 26-15: An Act Concerning Online Safety

The Act

Enacted text, verbatim · quoted in statute order

Conn. Pub. Act 26-15, Sec. 2(a)(2)

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Who is protected: covered employee, defined by the harms they work on§

(2) "Covered employee" [an employee of a frontier developer whose job is assessing, managing or addressing catastrophic-risk-type harms (Sec. 2(a)(2))] means any employee of a frontier developer who is responsible for assessing, managing or addressing the risk of (A) any unauthorized access to, or modification or exfiltration of, the model weights of a foundation model that causes (i) any death or bodily injury, or (ii) any damage to, or loss of, covered property, (B) any harm due to the materialization of any catastrophic risk, [foreseeable, material risk that a frontier model materially contributes to >50 deaths or serious injuries or >$1 billion in property damage or loss, via chemical, biological, radiological or nuclear uplift, or unsupervised cyberattack or violent conduct (Sec. 2(a)(1))] (C) any loss of control over a foundation model that results in any death or bodily injury, or (D) any use of a deceptive technique by a foundation model against its frontier developer that (i) subverts the frontier developer's control over, or monitoring of, the foundation model, (ii) demonstrates any materially increased catastrophic risk, and (iii) occurs outside of the context of an evaluation that is designed to elicit such use;

Effective: 2026-10-01 Conn. Pub. Act 26-15, Sec. 2 (effective-date designation) ↗
Binds you if: Definitional: who Sec. 2(c) and (d) protect, and who Sec. 2(b)(2) protects.
Goes to: n/a: definitional.
Compared with CA: Same class of employee, written out longhand. California defines covered employees by reference to 'critical safety incidents' (Lab. Code 1107(c)). Connecticut has no critical-safety-incident term, because it has no incident-reporting duty, so it inlines the same four harm categories into the definition: weight exfiltration, materialized catastrophic risk, loss of control, and model deception against the developer. Read against Lab. Code 1107(c), the four categories track item for item.

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Conn. Pub. Act 26-15, Sec. 2(a)(8)-(9)

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Who is covered: 10^26 operations, and $500M revenue for the larger tier§

(8) "Frontier developer" means any person doing business in the state who intends to train, initiates the training of or trains a foundation model and, in doing so, uses, or intends to use, a quantity of computing power that is greater than ten to the twenty-sixth power integer or floating-point operations, inclusive of any computing power used for original training and for any fine-tuning, reinforcement learning or other material modifications such person applies to a preceding foundation model; (9) "Large frontier developer" [a frontier developer whose annual gross revenues, counting everyone under common control with it, topped $500 million for the most recently completed calendar year (Sec. 2(a)(9)): California's threshold exactly] means any frontier developer [anyone doing business in Connecticut who trains, or intends to train, a foundation model using more than 10^26 integer or floating-point operations (Sec. 2(a)(8)): the same compute line California draws] who together with all persons who either directly or indirectly through one or more intermediaries control, are controlled by or are under common control with such frontier developer had annual gross revenues in excess of five hundred million dollars for the most recently completed calendar year;

Effective: 2026-10-01 Conn. Pub. Act 26-15, Sec. 2 (effective-date designation) ↗
Binds you if: Definitional: the two tiers the rest of Sec. 2 uses, frontier developer (compute only) and large frontier developer (compute plus revenue).
Goes to: n/a: definitional.
Compared with CA: California's two numbers, unchanged. Greater than 10^26 integer or floating-point operations inclusive of fine-tuning, and $500 million in annual gross revenues counting every person under common control. Three drafting differences with no evident substantive effect: Connecticut folds the compute test into the 'frontier developer' definition itself where California routes it through a separate 'frontier model' definition at 22757.11(i); Connecticut writes 'greater than ten to the twenty-sixth power' in words; and Connecticut adds an express 'doing business in the state' requirement that California leaves to general jurisdictional law.

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Conn. Pub. Act 26-15, Sec. 2(b)(1)-(2)

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No rule, policy or contract may authorize retaliation for safety reports§

(b) No frontier developer shall make, adopt, enforce or enter into any rule, regulation, policy or contract that provides that: (1) The frontier developer [anyone doing business in Connecticut who trains, or intends to train, a foundation model using more than 10^26 integer or floating-point operations (Sec. 2(a)(8)): the same compute line California draws] may discharge, discipline or otherwise penalize any employee of such frontier developer because such employee has engaged in any activity set forth in subsection (b) of section 31-51m of the general statutes; [Connecticut's general employee whistleblower statute, which protects reports of suspected legal violations to a public body; it predates this act and applies to all employees, not just covered employees] or (2) Any person with authority over a covered employee, [an employee of a frontier developer whose job is assessing, managing or addressing catastrophic-risk-type harms (Sec. 2(a)(2))] or any other covered employee who has authority to investigate, discover or correct an issue reported by the covered employee, may discipline or retaliate against such covered employee if such covered employee has reasonable cause to believe that an issue reported by such covered employee indicates that such frontier developer has engaged in any activity that poses a specific and substantial danger to the public health or safety due to a catastrophic risk. [foreseeable, material risk that a frontier model materially contributes to >50 deaths or serious injuries or >$1 billion in property damage or loss, via chemical, biological, radiological or nuclear uplift, or unsupervised cyberattack or violent conduct (Sec. 2(a)(1))]

Effective: 2026-10-01 Conn. Pub. Act 26-15, Sec. 2 (effective-date designation) ↗
Binds you if: Binds you if you are a frontier developer doing business in Connecticut: the 10^26-operation compute line, with no revenue floor for this subsection.
Goes to: No report receiver: the duty runs against the developer's own rules, policies and contracts. Enforced by the Attorney General; nothing here is published.
Compared with CA: Same protection, narrower one way and broader another. Connecticut forbids a frontier developer to adopt any rule, policy or contract 'providing for' the conduct quoted, the lead-in governing both parts. Narrower: Cal. Lab. Code 1107.1(a) bans the retaliation itself and protects disclosure to the Attorney General and to federal authorities, while Connecticut reaches only the rules, policies and contracts and names no outside recipient. Broader: subdivision (1) protects any employee for section 31-51m activity, not only covered employees. Connecticut's whistleblower protections are weaker overall.

Read Conn. Pub. Act 26-15, Sec. 2(b)(1)-(2) on cga.ct.gov ↗·Copy link

Conn. Pub. Act 26-15, Sec. 2(c)(1)

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Anonymous internal reporting channel, with updates, due January 1, 2027§

(c) (1) Not later than January 1, 2027, each large frontier developer [a frontier developer whose annual gross revenues, counting everyone under common control with it, topped $500 million for the most recently completed calendar year (Sec. 2(a)(9)): California's threshold exactly] shall establish and maintain a reasonable internal process through which (A) a covered employee [an employee of a frontier developer whose job is assessing, managing or addressing catastrophic-risk-type harms (Sec. 2(a)(2))] of such large frontier developer may anonymously submit a report to such large frontier developer disclosing any information that the covered employee believes, in good faith, indicates that such large frontier developer has engaged in any activity that poses a specific and substantial danger to the public health or safety due to a catastrophic risk, [foreseeable, material risk that a frontier model materially contributes to >50 deaths or serious injuries or >$1 billion in property damage or loss, via chemical, biological, radiological or nuclear uplift, or unsupervised cyberattack or violent conduct (Sec. 2(a)(1))] and (B) such large frontier developer shall provide reasonable updates to each covered employee who submits a report under subparagraph (A) of this subdivision disclosing (i) the status of the investigation such large frontier developer has undertaken in response to such report, and (ii) the actions such large frontier developer has taken in response to such report.

Effective: 2026-10-01 Conn. Pub. Act 26-15, Sec. 2 (effective-date designation) ↗
Binds you if: Binds you only if you are a large frontier developer (over 10^26 operations and over $500 million in revenues counting persons under common control) and the channel must exist by January 1, 2027.
Goes to: The large frontier developer itself. The channel is internal and anonymous; no agency receives the reports and nothing is published.
Compared with CA: Same channel, one parameter weaker and one narrower. Weaker: Connecticut requires 'reasonable updates' on the status of the investigation, where Cal. Lab. Code 1107.1(e)(1) requires 'a monthly update'. Narrower: California's channel also takes reports that the developer broke the SB 53 transparency chapter (Bus. & Prof. Code ch. 25.1), and Connecticut has no transparency chapter to report a violation of, so its trigger is catastrophic-risk danger only. Two clocks: the compliance deadline is January 1, 2027, inside a section that takes effect October 1, 2026.

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Conn. Pub. Act 26-15, Sec. 2(c)(2)(A)

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Reports and updates go to officers and directors at least quarterly§

(2) (A) Except as provided in subparagraph (B) of this subdivision, each report submitted under subparagraph (A) of subdivision (1) of this subsection, and each reasonable update provided pursuant to subparagraph (B) of subdivision (1) of this subsection, shall be shared with the officers and directors of the large frontier developer [a frontier developer whose annual gross revenues, counting everyone under common control with it, topped $500 million for the most recently completed calendar year (Sec. 2(a)(9)): California's threshold exactly] at least quarterly.

Effective: 2026-10-01 Conn. Pub. Act 26-15, Sec. 2 (effective-date designation) ↗
Binds you if: Binds you if you are a large frontier developer operating the Sec. 2(c)(1) internal channel.
Goes to: Officers and directors of the large frontier developer, at least quarterly. Internal only; not public, no agency copy.
Compared with CA: Materially identical to California. The conflict-of-interest carve-out at Sec. 2(c)(2)(B) falls outside the verbatim span above, so it is quoted here: "(B) If a covered employee has alleged wrongdoing by an officer or director of the large frontier developer in a report submitted under subparagraph (A) of subdivision (1) of this subsection, neither such report nor any reasonable update provided in response to such report pursuant to subparagraph (B) of subdivision (1) of this subsection shall be shared with such officer or director." California has the same carve-out at Lab. Code 1107.1(e)(2)(B).

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Conn. Pub. Act 26-15, Sec. 2(d)

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Posted or annual written notice of whistleblower rights§

(d) Each frontier developer [anyone doing business in Connecticut who trains, or intends to train, a foundation model using more than 10^26 integer or floating-point operations (Sec. 2(a)(8)): the same compute line California draws] shall provide to all of its covered employees clear notice of such covered employees' rights and responsibilities under this section by, at a minimum: (1) Ensuring that (A) a notice is posted and displayed at all times within any workplace maintained by such frontier developer disclosing the rights of covered employees under this section, (B) each newly hired covered employee [an employee of a frontier developer whose job is assessing, managing or addressing catastrophic-risk-type harms (Sec. 2(a)(2))] of such frontier developer receives a notice that is equivalent to the notice required under subparagraph (A) of this subdivision, and (C) each covered employee of such frontier developer who works remotely periodically receives a notice that is equivalent to the notice required under subparagraph (A) of this subdivision; or (2) At least annually providing a written notice to each covered employee of such frontier developer disclosing such covered employee's rights under this section, and ensuring each such covered employee receives, and acknowledges that such covered employee has received, such written notice.

Effective: 2026-10-01 Conn. Pub. Act 26-15, Sec. 2 (effective-date designation) ↗
Binds you if: Binds every frontier developer (no revenue floor), including for remote covered employees.
Goes to: The developer's own covered employees, by workplace posting or annual written notice. Nothing is filed with the state and nothing is public.
Compared with CA: Structurally a copy of California's notice duty. Cal. Lab. Code 1107.1(d) is the model, down to the posting-or-annual-notice election and the explicit remote-worker clause. Connecticut adds 'rights and responsibilities' framing in the lead-in and requires acknowledgment of receipt under option (2); California also requires that the notice be 'received and acknowledged'.

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Conn. Pub. Act 26-15, Sec. 2(e)

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$1,000 per violation: Attorney General only, no private right of action§

(e) Any frontier developer [anyone doing business in Connecticut who trains, or intends to train, a foundation model using more than 10^26 integer or floating-point operations (Sec. 2(a)(8)): the same compute line California draws] that violates any provision of subsections (b) to (d), inclusive, of this section shall be liable to the state for a civil penalty in an amount that does not exceed one thousand dollars per violation. The Attorney General may bring an action in the superior court for the judicial district of Hartford to collect such civil penalty and for any injunctive or equitable relief. No injunctive or equitable relief granted pursuant to this subsection shall be stayed pending appeal.

Effective: 2026-10-01 Conn. Pub. Act 26-15, Sec. 2 (effective-date designation) ↗
Binds you if: Applies to any frontier developer that violates Sec. 2(b), (c) or (d).
Goes to: The Attorney General, suing in the superior court for the judicial district of Hartford; penalties are payable to the state.
Compared with CA: Same enforcement architecture, with the cap three orders of magnitude lower. Both run on a civil penalty the Attorney General alone may pursue: $1,000 per violation in Connecticut against up to $1,000,000 per violation under Cal. Bus. & Prof. Code 22757.15(a). Connecticut adds a state-side fee-shift and a no-stay-pending-appeal rule for injunctive relief, in the sentence that follows the quoted span; California gives the same no-stay rule to whistleblower plaintiffs at Lab. Code 1107.1(i). Sec. 2 creates no private right of action.

Read Conn. Pub. Act 26-15, Sec. 2(e) on cga.ct.gov ↗·Copy link

Full text ↗

Every quote above is checked against the archived official text. This page covers the frontier-model duties only: read the whole act on cga.ct.gov ↗.

CACompared with: Conn. Pub. Act 26-15, Sec. 2(a)(2)

Cal. SB 53

Cal. Lab. Code § 1107(b) (SB 53, SEC. 4)·leginfo.legislature.ca.gov, official text ↗

(b) “Covered employee” means an employee responsible for assessing, managing, or addressing risk of critical safety incidents.

CACompared with: Conn. Pub. Act 26-15, Sec. 2(a)(8)-(9)

Cal. SB 53

Cal. Bus. & Prof. Code § 22757.11(h)-(j) (SB 53, SEC. 2)·leginfo.legislature.ca.gov, official text ↗

(h) “Frontier developer” means a person who has trained, or initiated the training of, a frontier model, with respect to which the person has used, or intends to use, at least as much computing power to train the frontier model as would meet the technical specifications found in subdivision (i). (i) (1) “Frontier model” means a foundation model that was trained using a quantity of computing power greater than 10^26 integer or floating-point operations. (2) The quantity of computing power described in paragraph (1) shall include computing for the original training run and for any subsequent fine-tuning, reinforcement learning, or other material modifications the developer applies to a preceding foundation model. (j) “Large frontier developer” means a frontier developer that together with its affiliates collectively had annual gross revenues in excess of five hundred million dollars ($500,000,000) in the preceding calendar year.

CACompared with: Conn. Pub. Act 26-15, Sec. 2(b)(1)-(2)

Cal. SB 53

Cal. Lab. Code § 1107.1(a) (SB 53, SEC. 4)·leginfo.legislature.ca.gov, official text ↗

(a) A frontier developer shall not make, adopt, enforce, or enter into a rule, regulation, policy, or contract that prevents a covered employee from disclosing, or retaliates against a covered employee for disclosing, information to the Attorney General, a federal authority, a person with authority over the covered employee, or another covered employee who has authority to investigate, discover, or correct the reported issue, if the covered employee has reasonable cause to believe that the information discloses either of the following: (1) The frontier developer’s activities pose a specific and substantial danger to the public health or safety resulting from a catastrophic risk. (2) The frontier developer has violated Chapter 25.1 (commencing with Section 22757.10) of Division 8 of the Business and Professions Code.

CACompared with: Conn. Pub. Act 26-15, Sec. 2(c)(1)

Cal. SB 53

Cal. Lab. Code § 1107.1(e)(1) (SB 53, SEC. 4)·leginfo.legislature.ca.gov, official text ↗

(e) (1) A large frontier developer shall provide a reasonable internal process through which a covered employee may anonymously disclose information to the large frontier developer if the covered employee believes in good faith that the information indicates that the large frontier developer’s activities present a specific and substantial danger to the public health or safety resulting from a catastrophic risk or that the large frontier developer violated Chapter 25.1 (commencing with Section 22757.10) of Division 8 of the Business and Professions Code, including a monthly update to the person who made the disclosure regarding the status of the large frontier developer’s investigation of the disclosure and the actions taken by the large frontier developer in response to the disclosure.

CACompared with: Conn. Pub. Act 26-15, Sec. 2(c)(2)(A)

Cal. SB 53

Cal. Lab. Code § 1107.1(e)(2)(A) (SB 53, SEC. 4)·leginfo.legislature.ca.gov, official text ↗

(2) (A) Except as provided in subparagraph (B), the disclosures and responses of the process required by this subdivision shall be shared with officers and directors of the large frontier developer at least once each quarter.

CACompared with: Conn. Pub. Act 26-15, Sec. 2(d)

Cal. SB 53

Cal. Lab. Code § 1107.1(d) (SB 53, SEC. 4)·leginfo.legislature.ca.gov, official text ↗

(d) A frontier developer shall provide a clear notice to all covered employees of their rights and responsibilities under this section, including by doing either of the following: (1) At all times posting and displaying within any workplace maintained by the frontier developer a notice to all covered employees of their rights under this section, ensuring that any new covered employee receives equivalent notice, and ensuring that any covered employee who works remotely periodically receives an equivalent notice. (2) At least once each year, providing written notice to each covered employee of the covered employee’s rights under this section and ensuring that the notice is received and acknowledged by all of those covered employees.

CACompared with: Conn. Pub. Act 26-15, Sec. 2(e)

Cal. SB 53

Cal. Bus. & Prof. Code § 22757.15(a)-(b) (SB 53, SEC. 2)·leginfo.legislature.ca.gov, official text ↗

(a) A large frontier developer that fails to publish or transmit a compliant document required to be published or transmitted under this chapter, makes a statement in violation of subdivision (e) of Section 22757.12, fails to report an incident as required by Section 22757.13, or fails to comply with its own frontier AI framework shall be subject to a civil penalty in an amount dependent upon the severity of the violation that does not exceed one million dollars ($1,000,000) per violation. (b) A civil penalty described in this section shall be recovered in a civil action brought only by the Attorney General.

Public Act No. 26-15 · An Act Concerning Online Safety

High-level summary

The Act

Also on the books in Connecticut