Does Colorado require AI impact assessments?

No longer. SB 26-189 (signed 2026-05-14) repealed and reenacted Colorado's AI Act, eliminating the impact-assessment requirement entirely. Colorado now instead requires deployers of automated decision-making technology (ADMT) to: give consumers clear interaction notice, disclose adverse consequential decisions within 30 days, allow correction of incorrect personal data, and provide meaningful human review and reconsideration. The statute formally takes effect 2026-08-12, but all compliance obligations — for deployers and developers alike — begin 2027-01-01.

What is the difference between developer and deployer obligations under the Colorado AI Act?

Last verified: May 31, 2026

Answer

Colorado's AI Act (reenacted by SB 26-189; the statute formally takes effect 2026-08-12 but all obligations begin 2027-01-01) splits obligations between deployers and developers. Deployers — businesses using ADMT to make or substantially influence consequential decisions — have 4 duties: interaction notice, adverse-outcome disclosure within 30 days, data-correction rights for consumers, and meaningful human review after an adverse decision. Developers — those who build ADMT — must supply technical documentation (intended uses, training-data categories, known limitations), notify deployers of material updates, and retain compliance records 3+ years. Both deployer and developer duties begin 2027-01-01. Impact assessments and risk management programs from SB 24-205 are gone. A company can be both developer and deployer if it builds and uses the same system.

Applicable Regulations

SB-26-189

Colorado AI Act — Automated Decision-Making Technology (SB 26-189, repeal & reenactment of SB 24-205)

enacted

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

Effective: 2027-01-01 Penalties: Enforced exclusively by the Colorado Attorney General; violations are treated as deceptive trade practices under the Colorado Consumer Protection Act. Before enforcement the AG must give 60 days' written notice and an opportunity to cure; this cure right sunsets 2030-01-01, after which enforcement may be immediate. The AG has stated no enforcement will occur until the mandatory rulemaking process concludes.

Full State Analysis

Colorado AI Regulations

Where this lands operationally

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