Connecticut Algorithmic Rent-Setting Software Ban

The statute's definition is specific, and it's worth reading closely rather than assuming it bans any pricing software. A revenue management device is software that uses one or more programmed or automated processes to calculate nonpublic competitor data about local or statewide rents or occupancy levels, for the purpose of advising a landlord whether to leave a unit vacant or how much rent the landlord may obtain.

[Cite: November 2025 Spec. Sess. P.A. 25-1, section 32]

Three elements have to be present together: an automated or programmed calculation process, nonpublic competitor data as an input, and a purpose of advising on either vacancy or rent amount. A tool missing any one of those three isn't what this section targets.

The category the statute is concerned with is specifically information not available to the general public, including actual rent amounts, occupancy levels, and lease start and end dates. This is the kind of granular, real-time data that pricing algorithms like the ones at the center of federal antitrust litigation against RealPage have been accused of pooling from competing landlords.

[Cite: November 2025 Spec. Sess. P.A. 25-1, section 32]

That framing matters for how the law is scoped. A tool built entirely on public data, listing sites, published market reports, census figures, doesn't fall within this definition, because the statute's concern is specifically with the nonpublic, competitor-sourced information that lets an algorithm effectively coordinate pricing across landlords who'd otherwise be setting rents independently.

Once software meets that definition, using it to actually set rental rates or occupancy levels for a residential dwelling unit is an unlawful practice under the Connecticut Antitrust Act. This isn't a labeling or disclosure requirement. It's a direct prohibition on the underlying conduct.

[Cite: November 2025 Spec. Sess. P.A. 25-1, section 32]

A landlord who subscribes to a revenue management platform and actually follows its pricing recommendations is the conduct this section targets, distinct from a landlord who might use similar software purely to view aggregated trends without acting on device-generated rent or vacancy advice.

The statute carves out two specific categories rather than leaving the exemption question open-ended. First, a product that publishes existing rental data in an aggregated manner, without recommending a future rate or occupancy level, isn't covered. Second, a tool used to establish rent or income limits under an affordable housing program's guidelines isn't covered either.

[Cite: November 2025 Spec. Sess. P.A. 25-1, section 32]

The first exemption is the one most property managers should look at closely. A market report that shows what comparable units in an area have historically rented for, without telling a specific landlord what to charge tomorrow, sits in that exempted category. A tool that takes the same underlying data and generates a specific recommended rent for a specific unit does not, even if it draws on similar sources.

The bill analysis for this section describes violators as subject to the Antitrust Act's existing investigation and enforcement provisions, including a civil penalty, without stating a dollar figure. Checking the underlying enforcement statute directly gives the actual numbers: an individual who violates the Antitrust Act faces a civil penalty of not more than $100,000, while any other person, which includes a corporation, faces a civil penalty of not more than $1,000,000.

[Cite: Connecticut General Statutes section 35-38]

That "any other person" phrasing is broader than just corporations specifically, though a corporation is the most common example in practice. A partnership, an LLC, or another business entity that isn't an individual would fall under the higher $1,000,000 ceiling as well.

Connecticut isn't acting alone here. It's one of ten states, along with California, Colorado, Illinois, Massachusetts, Minnesota, North Carolina, Oregon, Tennessee, and Washington, that joined the Department of Justice's federal antitrust lawsuit targeting algorithmic rent-pricing software. Several of those states, along with New York, have separately passed their own state-level restrictions on the practice.

[Cite: Baker McKenzie, insight on Connecticut's antitrust statute on algorithms]

That context is useful for a multistate property manager specifically, since a revenue management practice that's now prohibited in Connecticut may face a different legal standard, or none at all, in another state where the operator also has properties. Treating this as a Connecticut-specific compliance question, rather than assuming the same rule applies everywhere, matters for a portfolio spanning multiple jurisdictions.

Enforcement isn't limited to a single state agency acting alone. Because this is framed as a Connecticut Antitrust Act violation rather than a standalone housing statute, it's subject to that act's existing enforcement structure, which includes both state enforcement authority and a private right of action for parties harmed by a violation.

[Cite: November 2025 Spec. Sess. P.A. 25-1, section 32]

That dual enforcement path is a meaningful difference from many of the more narrowly tenant-facing provisions in this batch. A competitor, a tenant advocacy organization, or an individual tenant with standing could potentially bring a private claim, in addition to whatever the state pursues directly.

The statute doesn't name specific vendors or products, and it wouldn't be accurate to describe this as a ban on any particular company's software specifically. What it prohibits is a category of functionality: automated calculation using nonpublic competitor rent, occupancy, and lease data, to generate rent or vacancy advice for a specific landlord.

A property manager evaluating a pricing tool, existing or newly proposed, needs to ask specifically what data the tool ingests, whether that data includes nonpublic competitor information, and whether the tool's output is a specific rent or vacancy recommendation rather than an aggregated market trend. A vendor's marketing materials describing the tool as "market intelligence" or "pricing optimization" don't settle the question either way; the actual data sources and output format do.

The practical starting point is auditing any pricing or revenue management software currently in use against the statute's three-part definition: automated calculation, nonpublic competitor data as an input, and rent or vacancy advice as the output. A tool that clears all three elements needs to be discontinued for Connecticut properties, or replaced with one that relies only on public data or produces aggregated reporting rather than specific recommendations.

For a management company operating across several states, it's also worth confirming whether the same software is being used uniformly, and whether that uniform use creates exposure in Connecticut specifically even if the tool remains permitted elsewhere. Given the civil penalty exposure runs up to $1,000,000 for an entity, this is a compliance question worth resolving before a complaint or investigation forces the issue.