Colorado AI Act after SB 26-189: what applies on 1 January 2027
Checklist for 1 Jan 2027
- Inventory: which of your tools make or substantially shape consequential decisions about Colorado residents?
- Role: are you the developer (you build it) or deployer (you use it)? Obligations differ.
- Scope: ADMT = technology that processes personal data and generates predictions, recommendations, classifications, rankings or scores used to make, guide or assist a decision about a person. Consequential decision = access to, eligibility for, or compensation related to education, employment, housing, financial or lending services, insurance, health care, or essential government services (official bill summary).
- Developers of covered ADMT (from 1 Jan 2027): give deployers technical documentation on intended uses, categories of training data, known limitations, and instructions for appropriate use and human review; notify deployers of material updates.
- Developers and deployers: keep records showing compliance for at least 3 years.
- Deployers: clear and conspicuous notice at the point of interaction; within 30 days after an adverse outcome, a plain-language description of the ADMT's role; honour requests for personal data, correction, and meaningful human review and reconsideration.
- Contracts: get the developer documentation written into vendor agreements now, not at renewal.
- Watch the Attorney General rulemaking.
Enforcement
Enforced by the Attorney General under the Colorado Consumer Protection Act (a violation is a deceptive trade practice). Before 1 January 2030 the AG must give 60 days' notice and a chance to cure where a cure is possible. No new private right of action. The AG must adopt rules on the post-adverse-outcome disclosures by 1 January 2027 (official bill summary).
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Official and primary sources
- https://leg.colorado.gov/bills/sb26-189 (official: signed 14 May 2026, Session Laws ch. 131)
- https://www.nortonrosefulbright.com/en/knowledge/publications/18733d31/colorado-enacts-revised-ai-law
- https://www.crowell.com/en/insights/client-alerts/colorado-hits-reset-on-ai-regulation-sb-26-189-repeals-and-reenacts-the-colorado-ai-act
- https://www.coloradopolitics.com/2026/04/28/colorados-unprecedented-ai-law-cant-be-enforced-yet-judge-rules/
- https://www.eckertseamans.com/legal-updates/colorado-repeals-and-replaces-its-landmark-ai-statute-what-businesses-need-to-know