Connecticut employers with 100 or more workers have until October 1 to publish a plain-language guide explaining every overtime and pay-differential code on an employee’s paycheck, under a sweeping new labor law that folds pay transparency into routine payroll administration.
Public Act 26-12 requires covered employers to post the guide on their company website, in English, Spanish, and any other language commonly spoken by their workforce, covering codes like shift differentials, on-call pay, hazard pay, call-back pay, holiday and weekend pay, and geographic differentials. If the employer uses ten or more such codes, all of them must be listed, along with contact information for whoever handles employee pay disputes. Employers without a website are exempt from the posting requirement, and those using a third-party payroll provider can satisfy the rule by pointing employees to that provider’s own compliant guide. Details via Littler’s analysis of the act.
Why it matters: the pay code guide is one piece of a 120-plus-page bill that also expands wage-range disclosure on job postings, tightens disability accommodation notice timelines, and broadens lactation break protections, all effective the same October 1 date. For multistate employers, Connecticut becomes the latest state requiring HR and payroll to justify differential pay in writing rather than leave it buried in a timekeeping system employees never see.
The original insight: pay transparency laws have mostly targeted job postings and salary ranges. Connecticut is the first to reach backward into how pay is calculated after the offer, effectively forcing employers to document their own pay-code logic for an audience of employees, not auditors. That is a different compliance muscle than posting a salary band, and it will expose payroll systems that were never designed to explain themselves. It follows a pattern this publication has tracked all year of pay equity moving from a hiring-stage disclosure problem to a pay-stub-level one, the same shift now playing out in how courts are treating employer paperwork more broadly as evidence, not just as compliance box-checking.
