Connecticut Public Act 26-1 (Sections 50-57) requires specified employers who employ, directly or indirectly through a third party, workers at a warehouse distribution center to provide employees with written notice of work production quotas by August 1, 2026.
After that date, covered employers will be required to provide these written notices to new employees upon hire. While this new law affects only a specific set of Connecticut employers, the obligations for those employers are significant. This law makes Connecticut the sixth state to impose special requirements on employers to protect warehouse workers.[1]
Who is Covered?
This new law (the “Public Act”) covers certain employers with warehouse distribution centers in Connecticut. The Public Act uses the North American Industry Classification System (NAICS) codes to define “warehouse distribution center” for purposes of the law. Each NAICS code is a 2 to 6-digit number used by federal agencies to classify businesses by their primary economic activity. The Public Act applies only to employers that own or lease a warehouse or a warehouse complex defined by any of the following NAICS codes:
493110 (General Warehousing and Storage)
423 (Merchant Wholesalers, Durable Goods)
424 (Merchant Wholesalers, Nondurable Goods)
454110 (Electronic Shopping and Mail-Order Houses)
49210 (Couriers and Express Delivery Services)
452311 (Warehouse Clubs and Supercenters)
452319 (All Other General Merchandise Stores)
444110 (Home Centers)
Of these warehouse-type businesses, the Public Act applies only to those that employ or exercise control over the wages, hours or working conditions of:
(a) 250 or more employees at a single facility in Connecticut; or
(b) 1,000 or more employees at one or more facilities within the state.
These counts are based on the number of employees at any time within the prior 12 months. It includes all non-exempt employees, who are employed at a covered warehouse distribution center in Connecticut. It does not include drivers or couriers traveling to or from a warehouse distribution center or employees exempt from minimum wage and overtime laws.
What is a Quota?
A quota is a work production standard. The Public Act specifies four types of work production standards that qualify as “quotas” under the law. These include (i) when an employee is assigned to perform a specified productivity speed or quantified number of tasks or to handle a quantified amount of material within a defined time period; (ii) categorizing and measuring employee actions based on time spent performing tasks and not performing tasks within a defined time period; (iii) recording or tallying increments of time during which an employee (within a defined time period) is or is not doing a particular activity; or (iv) ranking an employee’s performance in relation to the performance of other employees. The law also sets forth a definition of “work speed data” as information the employer collects, stores, analyzes or interprets relating to an employee’s performance of a quota, carving out common personnel record items, such as qualitative performance reviews, wage statements, and other data.
The Public Act creates new restrictions on quotas at covered workplaces. For example, it provides that a quota that prevents compliance with laws requiring meal periods or employee use of the bathroom facilities (including travel time back and forth from the facilities) is unlawful. The Public Act also prohibits any quota that sets a performance standard (i) that measures an employee’s total output over a period of time that is shorter than the employee’s workday, or (ii) is based solely on ranking the employee in relation to the performance of others.
New Notice Requirements
As noted above, covered employers will need to provide employees who are subject to quotas with written notice about expectations and potential consequences of failure to meet a quota. The notice must be in writing and must describe each work production quota to which the employee is subject. The notice also must explain any potential adverse employment action that could result from the employee’s failure to meet the quota. Current employees must receive this notice by August 1, 2026. Employees hired after that date must be provided the notice upon hire.
Additionally, whenever an employer changes a work production quota, the employer must notify affected employee(s) of the change as soon as practicable (verbally or in writing) prior to the date on which the new quota is implemented. Employers must deliver a written description of the new quota to the employee no later than two business days after making the change.
Employers Must Maintain Records
Covered employers who impose quotas must maintain and preserve contemporaneous and accurate records of each employee’s work speed data, the aggregate work speed data for similar employees at the same warehouse distribution center, and the written notice provided to each employee for three years. Employers who do not require quotas or collect work speed data are not subject to this recordkeeping obligation.
What if an Employer Fails to Comply with the New Law?
An employer is precluded from taking any adverse action against an employee who fails to meet a quota if the employer did not provide the required notice or if the quota otherwise violates the Public Act’s provisions.
Furthermore, an employee who believes that satisfying the quota will violate the Public Act may request that the employer provide: (1) a written description of each quota to which the employee is subject; (2) a copy of their personal work speed data for the preceding 90 days; and (3) a copy of the aggregated work speed data for similar employees at the same warehouse distribution center for the prior 90 days. Former employees are also entitled to this information (as it relates to the final 90 days of their employment) but are limited by the Public Act to making only one such request. An employer must provide a written copy of any records requests no later than 10 calendar days after receipt of the request.
These provisions of the Public Act took effect July 1, 2026, potentially entitling employees and former employees to information concerning quotas and data from the March 1 – June 30 quarter of 2026 or earlier, in the case of former employees whose final 90 days of employment predate this period.
Remedies for Violation, Including a Private Right of Action
The Public Act authorizes an employee (or former employee) or the Attorney General (on behalf of a group of employees or former employees) to bring a civil action in the Connecticut Superior Court to seek damages, civil penalties, and injunctive relief. The court may also award reasonable attorney’s fees and costs to a prevailing plaintiff in the civil action, and if further authorized to assess a civil penalty of $1,000 for the first violation, $2,000 for the second violation, and $3,000 for a third or subsequent violations.
Retaliation is Prohibited
The Public Act includes a detailed section regarding retaliation, prohibiting adverse action, such as discharging or discriminating against an employee (or former employee) for making a request for information or filing a civil action. If an employer discharges, retaliates, discriminates or takes any adverse action against any employee (or former employee) within 90 days after the employee makes a request or files a civil complaint, the Public Act provides a rebuttable presumption that such adverse action violates the law.
Next Steps for Warehouse Employers
Managers at Connecticut warehouse distribution centers should review the Public Act carefully to assess whether this new law applies to their business. If so, they must take steps to comply, as the law took effect on July 1, 2026. Among other things, employers should review their recordkeeping and quota notification practices and ensure that mandatory notices regarding quotas are prepared and delivered to employees in time for the August 1st deadline.
Endnotes
Staff Attorney Elizabeth A. Ledkovsky contributed to this report.
[1] The others are California, New York, Minnesota, Washington and Oregon. Additionally, on July 13, 2026, Rhode Island enacted such a law, taking effect January 1, 2027.
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