Public Act 26-12 and Your Connecticut Payroll: Three Things That Are Now Insurance Problems

Connecticut's new labor and employment law adds an uncapped workers' comp benefit, expands pay transparency liability, and makes general contractors liable for a subcontractor's unpaid wages. Here is what each means for your coverage.
One Law, Three Separate Insurance Conversations
Connecticut Public Act 26-12, signed into law in May 2026, is a broad labor and employment bill, and most of the legal commentary on it is understandably written for HR and compliance audiences. Three of its provisions, though, land specifically on insurance programs — workers' compensation, employment practices liability, and general contractor risk — and deserve to be read that way, not just as compliance dates on a calendar.
1. An Uncapped Workers' Compensation Benefit for Teachers and Healthcare Workers
PA 26-12 provides that covered school and healthcare employees who are unable to work because they were assaulted in the course of their duties are entitled to 100% of their average weekly wage, with no cap on the benefit amount, for the resulting period of incapacity. Covered employees may also receive payment for medical care and for lost wages tied to court appearances connected to the assault.
For schools, hospitals, and healthcare employers, this is a direct workers' compensation cost question, not an abstract policy change. An uncapped wage-replacement benefit for a category of claim that was previously subject to the ordinary statutory cap changes the tail on exactly the kind of claim these employers are most exposed to. Review current experience and reserving practices for assault-related claims with your workers' compensation carrier, particularly if your organization employs staff in roles with elevated assault risk.
2. Pay Transparency: the Private Right of Action Was Retained, Not Created
Effective October 1, 2026, Connecticut employers of every size must include a wage or wage range, plus a general description of benefits, in both public and internal job postings. The detail that matters for an employment practices liability program is precise: the law continues to authorize a private right of action for violations — it was retained, not newly created — while the amendment eliminates punitive damages, leaving compensatory damages and attorney's fees available to a successful claimant.
That distinction matters for underwriting and for how you talk to your EPLI carrier about it. This is an existing exposure whose scope was narrowed on the damages side and whose compliance surface was widened to every employer regardless of size, not a brand-new cause of action appearing out of nothing. See our guide to Connecticut small-business workers' compensation requirements for how this fits alongside your other statutory obligations.
3. General Contractors Become Liable for a Subcontractor's Unpaid Wages
For construction contracts entered on or after January 1, 2027, a general contractor becomes jointly and severally liable for unpaid wages owed to a subcontractor's employees for work performed under that contract. An affected employee generally must give the general contractor 30 days' notice before bringing a claim. This sits alongside, but is legally distinct from, the workers' compensation principal-employer exposure already created by CGS §31-291 — see our guide to Connecticut's principal employer rule for that separate risk. Together, the two provisions mean a general contractor's subcontractor vetting now has two independent reasons to be rigorous: unpaid wages and uninsured injury are both exposures that can land on the GC rather than staying with the sub that caused them.
What to Do About Each
- Schools and healthcare employers: review workers' compensation reserving and premium impact for assault-related claims with your carrier now, ahead of any claim testing the new uncapped benefit.
- All employers, before October 1, 2026: update job posting templates for wage range and benefits disclosure, and confirm your EPLI program's understanding of the retained private right of action.
- General contractors, before January 1, 2027: tighten subcontractor payment verification and documentation alongside existing insurance certificate requirements — the two exposures now run in parallel.
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📅 Schedule a ConsultationThis is not a piece to win by restating the statute — legal counsel and employment law firms cover the compliance requirements directly. It exists to translate the parts of PA 26-12 that are genuinely insurance decisions. Review your workers' compensation program and construction insurance coverage, or contact New England Insurance to talk through how these three provisions actually affect your policies.
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