Large employers in Connecticut face a new requirement beginning October 1, 2026. Employers with 100 or more employees, including the state and political subdivisions, must create and maintain a guide explaining overtime pay codes and the employer’s most commonly used pay differentials, post that guide on the employer’s website in multiple languages, and provide employees with access to the guide at hire and through wage records. This new requirement appears intended to improve employee understanding of payroll entries and reduce disputes over hours, overtime, and premium pay.
The statute provides examples of pay differentials that may be part of the guide, including shift differentials, on-call pay, hazard pay, call-back pay, holiday pay, weekend pay, and geographic pay differentials. If applicable, the guide must include at least ten pay codes. The guide also must identify the office or individual designated to handle employee disputes regarding calculations of hours and pay differentials. The guide must be posted on the employer’s website in English, Spanish, and the other most common languages spoken by the employer’s workforce, and it must be updated whenever the employer adds a new pay code used for overtime or pay differentials.
In addition to posting the guide, covered employers must provide the website address for the guide to employees upon hire and must include that website address on each record of hours furnished to employees. The statute also permits an employer to comply with this notice requirement by providing a written copy of the guide to the employee in English and in the employee’s primary language. Employers using third-party payroll services are deemed compliant if the third party provides a guide that satisfies the statutory requirements. The law does not require an employer to create and maintain a website if it does not already have one, nor does it require employers to create new pay codes solely to comply.
Employers that meet the 100-employee threshold should begin preparing now by identifying all overtime-related pay codes and commonly used pay differentials, confirming whether existing payroll descriptions are accurate and employee-facing, determining which languages must be used for the guide, designating a contact person or office for payroll disputes, and coordinating with payroll vendors to confirm how the vendor can support compliance. Employers should also review onboarding materials and wage statement practices to ensure the required website address or written guide is provided at hire and referenced on wage records as required.
The labor and employment attorneys at Berchem Moses, PC can assist in complying with new employment laws. Please contact us if you need additional information about labor and employment matters affecting your workplace.
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