Crosswalk
Colorado AI Act ↔ EU AI Act
Colorado SB 24-205 is the first US state law directly modeled on the EU AI Act. Both target "high-risk" AI systems that make consequential decisions about consumers (credit, employment, housing, healthcare, education). The Colorado AG has explicitly said EU AI Act documentation may be used to demonstrate reasonable care.
This crosswalk maps Colorado SB 24-205, which was repealed and replaced in May 2026 by SB 26-189 (effective 1 January 2027). SB 26-189 drops the risk-management and impact-assessment duties mapped below; its notice, adverse-outcome explanation and human-review duties loosely correspond to EU AI Act Articles 26(11) and 86. Kept for teams migrating SB 24-205 programs.
| Colorado AI Act | EU AI Act | Notes |
|---|---|---|
§ 6-1-1701(9) High-risk AI system | Article 6 + Annex III High-risk AI systems | Substantially overlapping — CO adds housing, EU adds law enforcement. |
§ 6-1-1702(3) Risk management program | Article 9 Risk management system | Both continuous, documented. |
§ 6-1-1702(4) Impact assessment | Article 27 FRIA FRIA | CO CDPA analog; both apply pre-deployment and on modification. |
§ 6-1-1703 Deployer notice | Article 26(11) Notice to natural persons | Consumer disclosure. |
§ 6-1-1703(5) Adverse decision appeal | Article 26(11) Right to explanation | Direct analogue. |
§ 6-1-1706 AG enforcement | Article 99 Administrative fines | CO has 60-day cure period; EU has no equivalent cure. |
What to watch
Key differences
- · Colorado penalties = up to $20k/violation (CCPA); EU AI Act = up to €35M / 7% turnover.
- · Colorado covers Colorado consumers only; EU AI Act covers EU market.
- · Colorado has a 60-day cure period; EU has no cure period.
- · Colorado law enforced by AG exclusively; EU AI Act enforced by 27 national authorities + Commission.
- · Colorado does not regulate GPAI models; EU AI Act Chapter V explicitly does.
Primary sources
Where every mapping was verified
Next steps
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