Connecticut ends Transfer Act filings for sales from March 1, 2026; release-based cleanup applies
Since March 1, 2026 transactions no longer require Transfer Act filings, and cleanup duties arise when a release is discovered or occurs. A legislative study of brownfield problems under the new program is due January 1, 2027. Deal documents drafted around Transfer Act forms should be examined.
The Connecticut Department of Energy and Environmental Protection ("DEEP") Release-Based Cleanup Regulations (eRegulations PR2024-025, implementing Conn. Gen. Stat. §§ 22a-134pp to 22a-134xx as described on DEEP's program page) took effect on March 1, 2026 and replaced the Property Transfer Act as the way contaminated sites are investigated and remediated. DEEP's program page states that the Transfer Act sunsets on March 1, 2026, so that no filings are required for transactions occurring on or after that date, and its March 11, 2026 announcement states that the Transfer Act was replaced by the release-based program. A special act of 2026, SA 26-7, directs the brownfields working group to study brownfield development and remediation issues, including any caused by the release-based program, and to report by January 1, 2027, according to the Office of Legislative Research.
Release-Based Cleanup Regulations (eRegulations PR2024-025), implementing Conn. Gen. Stat. §§ 22a-134pp to 22a-134xx; Public Act 25-54; Special Act 26-7; DEEP news release, March 11, 2026