Regulatory Status
On 2026-05-14 Governor Polis signed SB 26-189, which repeals and reenacts the Colorado AI Act (originally SB 24-205). The new law abandons the risk-management / annual-impact-assessment model and replaces it with a disclosure-and-notice framework governing "automated decision-making technology" (ADMT) that makes or substantially influences "consequential decisions" (education, employment, housing, financial services, insurance, healthcare, government services). The statute formally takes effect 2026-08-12 (no safety clause), but all substantive compliance obligations — for both deployers and developers — begin 2027-01-01, which is the operative date for regulated businesses; the Attorney General's implementing rules are also due by 2027-01-01. The AG has stated he will not enforce until the mandatory rulemaking process concludes.
Key Requirements
Interaction Notice Deployers must give clear notice at the point of interaction when a consumer interacts with an automated decision-making technology (ADMT)
Adverse-Outcome Disclosure Provide a plain-language explanation within 30 days of an adverse consequential decision made or substantially influenced by an ADMT
Data Correction Right Allow consumers to request correction of factually incorrect personal data used by the ADMT
Meaningful Human Review Provide meaningful human review and reconsideration after an adverse consequential decision
Developer Documentation Developers must supply technical documentation (intended uses, known harmful uses, training-data categories, known limitations and risks, and instructions enabling meaningful human review), notify deployers of material updates, and retain compliance records for 3+ years. Like all duties under the act, these obligations begin 2027-01-01
Insurance Implications
Relevant policy types: E&O, CGL, Cyber, D&O
| Carrier | Endorsement | Status | Applies To | Filing Date | Source |
| Verisk | CG 40 47 | adopted | CGL | 2025-11-15 | verisk.com |
| W.R. Berkley | PC 51380 | filed | D&O, E&O, Fiduciary | 2025-12-01 | berkley.com |
| Verisk | CG 40 48 | adopted | CGL | 2025-11-15 | verisk.com |
| Verisk | CG 35 08 | adopted | Products/Completed Operations | 2025-11-15 | verisk.com |
Filing status based on carrier announcements and state DOI records.
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Compliance Gaps to Address
No AI governance policy for underwriting tools
Lack of human oversight in AI-driven coverage recommendations
No documentation of AI vendor risk assessments
Unaware of AI exclusion endorsements in own E&O coverage
No process to check placed policies for AI exclusion endorsements before binding
No E&O review of the brokerage's own AI tools against NAIC Model Bulletin expectations
Other Industries in This State
This Industry in Other States
Disclaimer: This content is provided for informational purposes only and does not constitute legal advice. AI regulations and insurance policy terms change frequently. Consult with a qualified attorney or insurance professional for advice specific to your situation. Gridex makes no warranties regarding the accuracy or completeness of this information.