The law is real. The compliance clock is running.
Connecticut’s CART Act, Public Act 26-15, was signed by Governor Ned Lamont in late May 2026. The hub covered the enactment when it happened. What’s new this week is the arrival of comprehensive compliance analyses from Morrison Foerster, Freshfields, and WilmerHale, the first detailed breakdowns of what the law actually requires companies to do and when.
Those analyses aren’t the primary authority. The statute is. But law firm client alerts published close to the effective date are often the fastest way compliance teams get a structured view of what’s coming, and the CART Act analyses arriving this week are detailed enough to be operationally useful, with one caveat that matters: all source URLs for those three client alerts were unavailable at press time. Every compliance requirement below is attributed to law firm analysis and should be treated as a starting point for verification, not a final answer.
According to Morrison Foerster’s analysis, subscription-based AI providers face written disclosure obligations and must obtain consumer consent before collecting payment, with that requirement taking effect October 1, 2026. That’s a 115-day window from today.
Connecticut CART Act, Compliance Verification Steps
- Access official PA 26-15 text at cga.ct.gov and verify subscription disclosure requirements
- Confirm October 1, 2026 disclosure effective date against statute
- If applicable: verify 10^26 FLOP frontier model threshold language
- If AEDT deployer: confirm cure period mechanics and December 31, 2027 expiration
- Review AI companion app restrictions for minor-facing products
The frontier model provisions are technically specific. Legal analysis indicates the law applies particular obligations, including whistleblower protections, to developers training models above a compute threshold of 10^26 FLOPs. That threshold places obligations on a narrow set of companies building at the frontier of large-scale model training. Compliance teams at those organizations should verify the exact threshold language against the official text of PA 26-15.
For automated employment decision tools, WilmerHale’s advisory reports that deployers have access to a cure period running through December 31, 2027, during which the Connecticut Attorney General can signal violations before enforcement begins. That’s a meaningful window, but it’s not indefinite. The cure period expires. What happens after December 31, 2027 is full enforcement, and organizations that haven’t addressed compliance by then don’t have a second window.
The AI companion provision has partial corroboration. The hub’s own June 2 coverage of PA 26-15 specifically referenced restrictions on AI companion applications involving minors, the full brief title was “Connecticut Signs PA 26-15: AI Companion Apps Must Detect Self-Harm and Restrict Minors.” That provision is the most independently confirmed element of the CART Act’s scope.The Connecticut General Assembly’s official publication of PA 26-15 at cga.ct.gov is the authoritative text. Before building a compliance program around any of the above, go there first.
Who This Affects
Don’t expect the law firm analyses to be wrong, Morrison Foerster, Freshfields, and WilmerHale don’t publish client alerts carelessly. But “probably right” isn’t the standard for compliance guidance. Verify the deadlines. Verify the thresholds. Verify the cure period mechanics. The official text is the authority.
The real question is which provision catches companies most off-guard. The October 1 subscription disclosure deadline is less than four months away. If your organization operates subscription-based AI services in Connecticut or to Connecticut consumers, that clock is running regardless of when the law firm analysis arrived in your inbox.