AI Compliance Vendors

When does the Colorado AI Act take effect?

The original Colorado AI Act (SB 24-205) was repealed in May 2026; its replacement, SB 26-189, takes effect January 1, 2027 with notice, explanation and documentation duties for automated decision-making technology.

Last updated September 27, 2026 · Every fact traceable to a public source

SB 24-205, signed in May 2024, was the first comprehensive US state AI law. SB 25B-004 moved its effective date from 1 February 2026 to 30 June 2026, a federal court order blocked its enforcement on 27 April 2026, and in May 2026 Colorado repealed it and enacted SB 26-189 in its place. SB 26-189 regulates automated decision-making technology (ADMT) that materially influences consequential decisions about consumers — for example in employment, education, housing, financial services, insurance, healthcare and essential government services — and takes effect 1 January 2027.

Does SB 24-205 still apply?

No. SB 24-205 was repealed and replaced by SB 26-189 in May 2026, so its 1 February 2026 and 30 June 2026 dates and its risk-management and impact-assessment duties no longer apply.

Who is in scope of SB 26-189?

Developers of ADMT and deployers that use ADMT in consequential decisions about Colorado consumers. Published summaries describe ADMT as technology that processes personal data and whose output materially influences — is a non-de minimis factor in — a consequential decision.

What are the key duties under SB 26-189?

Developers must give deployers documentation on intended uses, known limitations and risks, categories of training data and instructions for appropriate use. Deployers must give consumers clear notice when ADMT is used, explain adverse outcomes in plain language within 30 days, and offer correction of inaccurate personal data and meaningful human review where commercially reasonable. Both must keep records for at least three years.

How is it enforced?

By the Colorado Attorney General under the Colorado Consumer Protection Act; there is no private right of action. Businesses get a 60-day opportunity to cure before enforcement, a provision that sunsets on 1 January 2030. Confirm details against the enacted text with counsel.

How does it compare to the EU AI Act?

SB 26-189 is much narrower: it focuses on transparency to consumers and documentation between developers and deployers, with no impact assessments, conformity assessment or CE marking. Work done for the EU AI Act (whose Annex III high-risk rules now apply from 2 December 2027) still produces much of the documentation Colorado deployers need.

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