Conn. Gen. Stat. » Title 31 — LABOR · Chapter 568 — Workers' Compensation Act
Connecticut General Statutes

Conn. Gen. Stat. § 31-303 (2025)

Day when compensation payments become due. Penalty for late payments

✓ laws through the 2024 session: the source has not yet published 2025 Public Acts (checked Sept. 2026)
Find cases: SyfertCases citing this section CT-CGAcga.ct.gov (official) JustiaTitle on Justia CornellLII Search CasesGoogle Scholar
Payments agreed to under a voluntary agreement shall commence on or before the twentieth day from the date of agreement. Payments due under an award shall commence on or before the twentieth day from the date of such award. Payments due from the Second Injury Fund shall be payable on or before the twentieth business day after receipt of a fully executed agreement. Any employer who fails to pay within the prescribed time limitations of this section shall pay a penalty for each late payment, in the amount of twenty per cent of such payment, in addition to any other interest or penalty imposed pursuant to the provisions of this chapter.

(1959, P.A. 580, S. 21; 1961, P.A. 491, S. 26; P.A. 89-70, S. 1, 2; P.A. 93-228, S. 14, 35; P.A. 04-47, S. 1.)

History: 1961 act entirely replaced previous provisions; P.A. 89-70 added the provision allowing the second injury fund ten business days to make payments; P.A. 93-228 added provision imposing 20% penalty, in addition to interest and other existing penalties, on compensation payments which are paid more than ten days after the date of the agreement or award, effective July 1, 1993; P.A. 04-47 replaced references to “tenth” day with references to “twentieth” day, effective May 4, 2004.

Cited. 233 C. 14. Phrase “payments due under an award” does not encompass attorney's fees included in award pursuant to Sec. 31-300, and such attorney's fees are not subject to penalty as a late payment thereunder. 260 C. 21.

Penalty provision applicable to workers' compensation cases resolved by stipulation; penalty provision may be applied before effective date. 54 CA 841. Section is not ambiguous and, when read with Sec. 31-301(f) and (g), requires payment to commence within 20 days of order for payment pending appeal of award or imposition of 20 per cent late fee. 114 CA 822.

(Return to Chapter
Table of Contents)		 (Return to
List of Chapters)		 (Return to
List of Titles)

Notes of Decisions
Cited in 15 cases (3 in the last 5 years), 1995–2026 · leading case: Schiano v. Bliss Exterminating Co., 792 A.2d 835 (Conn. 2002).
Sort: Relevance Newest Treatment
Schiano v. Bliss Exterminating Co., 792 A.2d 835 (Conn. 2002). · cites it 46× “The principal issue in this appeal is whether the defendant second injury fund (fund) maybe assessed *23 a penalty, pursuant to General Statutes § 31-303 1 of the Workers’ Compensation Act (act), on attorney’s fees it paid after the prescribed time limitation for “[p]ayments due…”
Casey v. Ne. Utils., 731 A.2d 294 (Conn. 1999). · cites it 45× “The dispositive issue in this appeal is whether the defendant second injury fund (fund), may *367 be ordered to pay penalties for failing to make timely payments pursuant to General Statutes § 31-303. 1 The fund appeals from a decision of the compensation review board (board)…”
Davis v. Forman Sch., 738 A.2d 697 (Conn. App. Ct. 1999). · cites it 26× “This appeal arises from the decision of the workers’ compensation review board (board) affirming an award to the plaintiff, Louella Davis, pursuant to General Statutes § 31-303, 1 together with a penalty of 20 percent of such award against the defendants, Royal Insurance Company…”
Hummel v. Marten Transp., Ltd., 970 A.2d 834 (Conn. App. Ct. 2009). · cites it 23× “(Marten), and its insurer, Crawford & Company, appeal from the decisions of the workers’ compensation review board (board) affirming the workers’ compensation commissioner’s (1) finding of compensability, (2) award of a penalty pursuant to General Statutes § 31-303 and (3)…”
Spears v. Garcia, 818 A.2d 37 (Conn. 2003). · cites it 2× “45 (“legislative history of [General Statutes] § 31-303 and the language of other provisions of the [Workers’ Compensation Act] relating to the commissioner’s authority to make an award of fees constitutes compelling evidence that, despite the statutory language, the *30…”
Costantino v. Skolnick, 988 A.2d 257 (Conn. 2010). · cites it 4× “2d 835 (2002) (deciding that, before court could reach issue raised as to whether attorney's fees fell within exclusion to General Statutes § 31-303, statute assessing interest on late payments due under workers' compensation award, it must decide threshold issue as to whether…”
Harpaz v. Laidlaw Transit, Inc., 942 A.2d 396 (Conn. 2008). · cites it 2× “93-228, § 14, now codified at General Statutes § 31-303. Prior to 1993, the act already provided penalties for untimely payment, one of which permitted a court to assess 12 percent interest and attorney’s fees for an employer’s failure either to contest liability in a timely…”
Dos Santos v. F. D. Rich Constr. Co., 658 A.2d 83 (Conn. 1995). · cites it 3× “” If, as argued by the fond, the term “agreement” in the act was intended always to have the exact meaning of “voluntary agreement,” then the legislature likely would have used the term “agreement” consistently throughout the act and would have had no need to use the specific…”
DeOliveira v. Liberty Mut. Ins., 870 A.2d 1066 (Conn. 2005). · cites it 2× “” General Statutes § 31-303. The legislature has empowered the commission to take other measures to ensure prompt payment of benefits and to address the wrongful withholding of benefits.”
Gill v. Brescome Barton, Inc., 68 A.3d 88 (Conn. App. Ct. 2013). · cites it 2× “On appeal to this court, Liberty Mutual contends that the commissioner’s finding and award is erroneous as a matter of law because enforcement of the 2010 agreement pursuant to General Statutes § 31-303 was not identified in the notice of the formal hearing as an issue to be…”
Ferraro v. Ridgefield Eur. Motors, Inc., 313 Conn. 735 (2014). · cites it 6× “Before the commissioner’s findings were issued, this court had issued a decision holding that the defendant was subject to § 31-303.”
Fenton v. Connecticut Hosp. Ass'n Workers' Comp. Trust, 752 A.2d 65 (Conn. App. Ct. 2000). “and § 31-303, despite both oral and written demands therefor by the Plaintiff to the Respondents, have not been made.”
Show all 15 citing cases →
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.