What is the Colorado AI Act?
Answer
The Colorado AI Act is the state law on AI used to make consequential decisions about people, such as hiring, lending, housing and insurance. Colorado replaced the original 2024 act with SB 26-189, signed May 14, 2026, per the Colorado General Assembly. Its developer and deployer duties start Jan. 1, 2027, per a July 9, 2026 National Law Review summary.
Status as of Oct. 28, 2026
- May 17, 2024: the Governor signed SB 24-205, with developer and deployer duties set to begin Feb. 1, 2026, per the Colorado General Assembly.
- Aug. 28, 2025: SB 25B-004 was signed and moved those duties to June 30, 2026, per the General Assembly.
- April 9, 2026: xAI sued in federal court in Colorado to block the law, and a magistrate judge stayed enforcement on April 27, 2026, per Squire Patton Boggs on May 1, 2026.
- May 14, 2026: the Governor signed SB 26-189, which repeals and reenacts the 2024 act around automated decision making technology. The General Assembly lists it as Session Law Chapter 131, checked Oct. 28, 2026.
- Jan. 1, 2027: the new duties take effect, per Lowenstein Sandler on June 8, 2026, and the National Law Review on July 9, 2026.
What SB 26-189 requires
- Developers must give deployers technical documentation on intended uses, training data categories, known limitations and human review, starting Jan. 1, 2027, per the General Assembly bill page checked Oct. 28, 2026.
- Deployers must give consumers clear notice when covered technology is used in a consequential decision, per the same page.
- Within 30 days of an adverse decision, deployers must give a plain language description of the technology's role, per the same page.
- Consumers can request their data, correct factual errors and ask for meaningful human review after an adverse outcome, per the same page.
- Developers and deployers must keep compliance records for at least 3 years, per the same page.
Who enforces it
The Colorado Attorney General enforces the law under the Colorado Consumer Protection Act, and a violation counts as a deceptive trade practice, per the General Assembly bill page checked Oct. 28, 2026.
Before Jan. 1, 2030, the Attorney General must give 60 days' notice and a chance to cure before filing an action. The law creates no new private right of action, and the Attorney General must adopt disclosure rules by Jan. 1, 2027, per the same page.
The National Law Review wrote on July 9, 2026 that the xAI case remained stayed and that SB 26-189 renders many of its claims moot.
Does it apply to your company
- Your product processes personal data and produces a score, prediction or recommendation used in a decision about a person.
- That decision affects education, employment, housing, lending or financial services, insurance, health care or government services.
- You build the system for others to use, which makes you a developer, or you use it on consumers, which makes you a deployer.
Check whether AI engines describe your product and how it makes decisions correctly before Colorado buyers ask.
Sources
- SB26-189 Automated Decision-Making Technology · Colorado General Assembly, May 14, 2026Supports: Signing date, session law status, developer and deployer duties, consumer rights and enforcement terms, checked Oct. 28, 2026.
- SB24-205 Consumer Protections for Artificial Intelligence · Colorado General Assembly, May 17, 2024Supports: The original act's signing date and its Feb. 1, 2026 start for developer and deployer duties.
- SB25B-004 Increase Transparency for Algorithmic Systems · Colorado General Assembly, Aug. 28, 2025Supports: The delay of SB 24-205's duties to June 30, 2026.
- The Colorado AI Act hits a wall: litigation, legislative uncertainty and an enforcement standstill · Squire Patton Boggs, Privacy World, May 1, 2026Supports: The xAI lawsuit filing date and the April 27, 2026 stay of enforcement.
- Colorado's AI landscape: how B2C companies should navigate uncertainty · Lowenstein Sandler, June 8, 2026Supports: The Jan. 1, 2027 effective date and the Attorney General's decision not to enforce the original law.
- Colorado's SB 26-189: understanding the new automated decision-making technology law · National Law Review, July 9, 2026Supports: Duties for developers and deployers from Jan. 1, 2027 and the status of the xAI case.
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General information, not legal advice.
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