Direct answer
No longer. SB 26-189 (signed May 14, 2026) repealed and reenacted Colorado's AI Act, eliminating the impact-assessment requirement entirely. Deployers of automated decision-making technology must instead give clear interaction notice, disclose adverse consequential decisions within 30 days, allow correction of inaccurate personal data, and provide meaningful human review. The statute takes effect August 12, 2026, but all compliance obligations begin January 1, 2027.
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 SB 26-189 (signed 2026-05-14) repealed and reenacted Colorado's AI Act, eliminating the impact-assessment requirement entirely.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.
Scope
Answers the impact-assessment question under current Colorado law (SB 26-189), which repealed and reenacted the original Colorado AI Act. It covers what replaced the assessment requirement; it does not detail Illinois or Texas hiring law except by contrast. Obligations begin January 1, 2027.
Operational implication
The repealed impact assessment is replaced by operating duties, not paperwork relief. From 2027 deployers must run interaction notice, a 30-day adverse-outcome disclosure clock, data-correction handling, and meaningful human review — a trained reviewer with authority to override. Those are workflow controls, plus 3-year per-decision record retention, which employers should design now.
Applicable Regulations
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.
Where this lands operationally
Gridex turns the compliance or coverage question into operated workflow controls: intake, review points, audit trails, and the places a person stays in the decision.
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.