AI in Employment Decisions: A Compliance Toolkit

Employers using AI in hiring now answer to multiple state standards, and they do not line up. California's FEHA regulations took effect October 1, 2025, Texas TRAIGA on January 1, 2026, and the first of Connecticut's obligations arrives October, 1 2026.

This toolkit collects DCI's cheat sheets and trackers for each framework, so a compliance team can see what applies where without reading three statutes side by side.

What Employers Need to Know

• Texas TRAIGA turns on intent. Unequal outcomes alone do not establish a violation, which is a materially different standard from Title VII.

• Connecticut's Act (SB 5, Public Act 26-15) removes AI use as a defense to a discrimination complaint from October 1, 2026, and requires disclosure of AI-related layoffs under the state WARN Act on the same date.

• Connecticut's disclosure and pre-decision notice obligations do not begin until October 1, 2027, so employers have a year to build the notice process rather than retrofit it.

• Texas and Connecticut both route enforcement exclusively through the state Attorney General. Neither creates a private right of action, and both provide a 60-day cure period.

• Texas penalties run from $10,000 to $12,000 per curable violation and $80,000 to $200,000 for violations that cannot be cured.

• Passing a state AI standard does not resolve federal exposure. A system that survives TRAIGA's intent test can still produce adverse impact under Title VII.

Frequently Asked Questions