Beginning October 1, providers of certain consumer-facing generative AI systems must disclose usage limits and possible feature restrictions before a subscription begins or renews.

Beginning October 1, 2026, providers of certain consumer-facing generative AI systems must give Connecticut consumers written notice of key terms before starting a subscription. At renewal, they must disclose specified limits and provider rights that are new or have changed.

Consumers must accept the applicable terms in writing.

Providers cannot start or renew a covered subscription, or charge for it, until they have provided the required notice and received that acceptance.

Which AI subscriptions are covered

The requirements apply to companies doing business in Connecticut that create, code or otherwise produce a generative AI system with more than one million users per month.

The system must be publicly available to consumers for personal use and offered through a subscription.

Connecticut initially passed a much broader provision in May. A second law, signed days later, replaced it with this narrower requirement for large, consumer-facing generative AI systems.

The law covers Connecticut residents using the service personally. It does not cover people using it for work or acting on behalf of a business, nonprofit or government organization.

What providers must disclose

Before a subscription begins, covered providers must disclose information that would help a reasonable consumer decide whether to purchase or maintain it.

That includes limits the provider may impose on the service. The law specifically mentions tokens, generated or modified images, and transcription services. It also covers restrictions imposed in response to a customer’s conduct.

Providers must disclose whether they have the right to reduce or eliminate access to a feature, or lower the quantity or quality of functionality included with the subscription.

At renewal, consumers must be told about specified limits that will be introduced or changed for the new term. Providers must also disclose new or changed authority to reduce or remove functionality.

Consumers must accept the applicable terms in writing. The law does not specify the screen, button language or process providers should use.

Enforcement rests with the attorney general

A violation will be treated as an unfair or deceptive trade practice under Connecticut law.

The Connecticut attorney general has exclusive enforcement authority. The provision does not create a private right of action, so consumers cannot bring individual lawsuits or class actions based on it.

Insider Take

Connecticut’s law is unusually specific. It doesn’t cover every AI-powered subscription or every generative AI provider. It targets large companies selling consumer generative AI subscriptions.

Industry-specific subscription rules aren’t new. What stands out is Connecticut’s decision to write renewal requirements for one fast-changing digital product category.

The law also reaches beyond price, renewal timing and cancellation. It treats usage limits, feature access and changes in functionality as material subscription terms.

The question for the wider subscription industry is whether other states will follow that model. Instead of relying only on broad automatic renewal laws, lawmakers could create different requirements for particular products or groups of providers.

The law’s direct reach is narrow. The regulatory approach could travel much further.

Sources

• Connecticut Public Act 26-100
• Connecticut Public Act 26-15
• Connecticut General Statutes, Chapter 743jj