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October 2026 Employer Compliance Calendar: Key HR, Payroll, Benefits and Workforce Management Deadlines

Staying ahead of rapidly changing compliance requirements isn't just good practice, it's essential to protect your organization and your people. From evolving payroll requirements to shifting workforce management rules, the stakes are high for employers navigating today's regulatory landscape.

Key takeaways:

This calendar complements our Eye on State and Local update by highlighting key HR, payroll, benefits and workforce management compliance requirements including who they affect, when they occur and what you should do to prepare.

Included in this update are effective dates for Alabama, Connecticut, Maryland, South Carolina and Washington.

Alabama

Ban on non-disclosure provisions related to sexual abuse takes effect

Impacted employers: All Alabama employers

Effective date: October 1, 2026

Summary: Employers may not include any provision prohibiting an individual from disclosing an act of sexual abuse or facts related to an act of sexual abuse in any:

  • Nondisclosure agreement.

  • Confidentiality agreement.

  • Employment agreement.

  • Settlement agreement.

  • Any other type of agreement.

Action items:

  • Review potentially impacted template agreements with the assistance of legal counsel and revise these agreements as needed to help ensure compliance with the law.

  • Ensure individuals responsible for drafting or negotiating impacted agreements are aware of the new requirements.

Connecticut

New rules for pay codes

Impacted employers: Connecticut employers with 100 or more employees

Effective date: October 1, 2026

Summary: Employers with 100 or more employees must create, post and distribute a guide to employees explaining the pay codes used for overtime and common pay differentials.

Action items:

  • Inventory all overtime and differential pay codes used in payroll systems.

  • Create a plain-language pay-code guide.

  • Develop a process for distributing the guide to new hires.

  • Establish a process for updating the guide whenever new pay codes are added.

  • Review the law in full and determine whether any additional changes to policies and practices should be made.

Pay transparency law takes effect

Impacted employers: All Connecticut employers

Effective date: October 1, 2026

Summary: Employers must disclose in all internal and external job postings or prior to any compensation discussion with an applicant:

  • The wage range for each position.

  • A general description of benefits.

Action items:

  • Review all job posting templates.

  • Develop standard benefit summaries for inclusion in postings.

  • Train recruiters and hiring managers regarding disclosure obligations.

  • Review internal promotion and transfer posting practices.

  • Review the law in full and determine what additional changes to policies and practices should be made.

New rules for promissory notes

Impacted employers: All Connecticut employers

Effective date: October 1, 2026

Summary: Employers may not require any employee or applicant to sign a promissory note agreeing to pay the employer a sum of money if they leave before a certain period of time.

Action items:

  • Identify agreements that may be construed as prohibited promissory notes.

  • Review onboarding documentation and applicant materials.

  • Consult legal counsel as needed.

  • Review the law in full and determine whether any changes to policies and practices should be made. 

Expanded lactation break requirements

Impacted employers: All Connecticut employers

Effective date: October 1, 2026

Summary: Employers must provide reasonable break times for employees to express breast milk in the workplace in addition to already scheduled breaks.

Action items:

  • Review lactation accommodation policies.

  • Create or update accommodation request procedures.

  • Evaluate availability of lactation spaces at Connecticut worksites.

  • Train managers and supervisors on accommodation requirements.

  • Review the law in full and determine whether any changes to policies and practices should be made.

Enhanced workers’ compensation benefits

Impacted employers: Connecticut employers employing healthcare workers and certain teachers

Effective date: October 1, 2026

Summary: Employees of healthcare providers and certain teachers will be eligible to receive enhanced workers' compensation benefits if they are unable to work due to a physical or negligent assault while performing their duties within the scope of their employment.

Action items:

  • Identify impacted employee populations.

  • Update workers' compensation administration procedures.

  • Coordinate with workers' compensation carriers and TPAs.

  • Train HR and leave administrators on eligibility requirements.

  • Review workplace violence response protocols.

  • Review the law in full and determine whether any changes to policies and practices should be made.

New ADA notice

Impacted employers: All Connecticut employers

Effective date: October 1, 2026

Summary: Employers must provide written notice or post in the workplace about employee rights to reasonable accommodations under the Americans with Disabilities Act. The law directs the Connecticut Department of Labor to create a notice. An employer may comply with the notice requirements by displaying the version created by the department in a conspicuous place, accessible to employees, at the employer's place of business.

Action items:

  • Monitor for issuance of the Connecticut DOL model notice.

  • Update onboarding materials.

  • Verify physical and electronic posting processes.

  • Review accommodation policies for consistency with notice language.

  • Review the law in full and determine whether any changes to policies and practices should be made.

Artificial Intelligence Responsibility and Transparency Act notice provisions take effect

Impacted employers: Connecticut employers that use automated employment-related decision technology (AEDT) in Connecticut. 

Effective date: October 1, 2026, for the provisions generally. The WARN-related disclosure and nondiscrimination amendments also take effect October 1, 2026. However, the employer AEDT interaction-disclosure and pre-decision notice requirements apply to covered deployments made on or after October 1, 2027.

Summary: Connecticut has enacted legislation that adds rules for employers that use automated employment-related decision technology, amends the state’s nondiscrimination law and establishes certain disclosure requirements for federal mass layoff notices. 

Action items:

  • Inventory any employment tools used in Connecticut and determine whether any qualify as AEDT under the new law, consulting legal counsel as needed.

  • Identify where tool output is used to make, or is a substantial factor in making, employment-related decisions, such as hiring, promotion, training, discipline or discharge.

  • Prepare plain-language interaction disclosures for Connecticut applicants and employees who interact with AEDT, unless the interaction would be deemed obvious.

  • Build a written pre-decision notice process that includes the required information.

  • Coordinate with vendors/developers to obtain the information needed for compliance.

  • Update WARN-related notice procedures (if applicable) to disclose whether the layoffs are related to AI or another technological change.

  • Review the law in full and determine whether any changes to policies and practices should be made.

Notice requirements for electronic monitoring expanded

Impacted employers: Connecticut employers that conduct electronic monitoring of employees on the employer’s premises

Effective date: October 1, 2026

Summary: New legislation expands employer notice requirements for electronic monitoring of employees. Beginning October 1, 2026, covered employers must disclose not only the types of electronic monitoring that may occur, but also the specific locations on the employer’s premises where monitoring may occur. 

Action items:

  • In addition to revising employee monitoring notices and procedures to align with the changes, covered employers should:

  • Review workplace postings and ensure the notice is posted in a conspicuous place, including in each specific location where monitoring may occur.

  • Create a written plain-language notice for each employee hired on or after October 1, 2026, and provide it before the employee begins employment.

  • Map monitored spaces on the employer’s premises so the employer can describe locations with enough specificity to support compliant notice and posting. 

Hours worked definition amendments take effect

Impacted employers: Connecticut employers that require employees to undergo security screenings.

Effective date: October 1, 2026

Summary: The definition of compensable “hours worked” under Connecticut law will include the time an employee spends in security screenings required by an employer. This amendment follows the Del Rio v. Amazon.com Services, Inc. decision, in which the Connecticut Supreme Court held that mandatory on-premises security screening time is compensable under Connecticut law.

Action items:

  • Assess whether security-screening time is currently captured.

  • Update timekeeping procedures to capture compensable screening time.

  • Evaluate impacts on overtime calculations.

  • Review timekeeping policies and practices and ensure that they adhere to applicable law.

Maryland

Mandatory employer meetings on political or religious matters are banned

Impacted employers: All Maryland employers

Effective date: October 1, 2026

Summary: Maryland has enacted legislation prohibiting employers from taking adverse action against an individual because the individual refuses to attend an employer-sponsored meeting regarding the employer's opinions on religious or political matters. The law also requires employers to display a poster in the workplace and provide a notice to new hires.

Action items:

  • Monitor the Labor Commissioner’s website, and display the required poster and furnish the required notice once the Labor Commissioner makes them available.

  • Review policies and practices to help comply with the changes.

  • Train supervisors on the new law.

South Carolina

Civil Air Patrol Leave Act takes effect

Impacted employers: All South Carolina employers

Effective date: October 1, 2026

Summary: Employers must provide emergency response leave and training leave to eligible employees for certain Civil Air Patrol purposes.

Action items:

  • Update leave policies and procedures and train managers on how to respond to Civil Air Patrol leave requests.

Washington

Immigrant Worker Protection Act takes effect

Impacted employers: All Washington employers

Effective date: The law took effect on June 11, 2026, but the employer requirements will take effect on October 1, 2026.

Summary: Employers must post a notice in the workplace informing employees of their rights under the law. Additionally, employers must provide written notice to all employees within five business days of receiving a federal agency notification of inspection of Form I-9 and related records. Employers must also provide written notice and any obligations to any employee affected by the results of the inspection within five business days along with additional details.

Action items:

  • Review the law to understand additional details.

  • Post the required poster and distribute required notices as needed to help ensure compliance with the law.

  • Consult legal counsel as needed to navigate the interplay between federal and state law and to help respond to Form I-9 audits and any related enforcement actions.

About ADP

ADP carefully monitors federal and state legislative and regulatory developments in key areas including human resources, payroll, tax, benefits administration, and workforce management to help ensure that ADP systems are updated as relevant laws evolve.

We are committed to assisting businesses with increased compliance requirements resulting from rapidly evolving legislation and regulations. Our goal is to help minimize your administrative burden so that you can focus on running your business.

About this Update

This article is for general informational purposes only and does not constitute legal advice. Nothing herein should be construed as legal advice or a legal opinion. This summary is high level and may not address all details, requirements, or compliance obligations related to the developments described. Additionally, the compliance events referenced may have changed since publication. Before acting or refraining from action based on this information, consult a qualified attorney for advice tailored to your specific situation.

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