Skip to content
114 days remaining

Colorado ADMT Law Effective Date: January 1, 2027 (SB 26-189)

Colorado's original AI Act (SB 24-205) was repealed before it took effect. Its replacement, SB 26-189 — a narrower law covering "automated decision-making technology" (ADMT) — takes effect January 1, 2027. It applies when ADMT "materially influences" a "consequential decision" about a Colorado resident in employment, credit, education, healthcare, or housing. Unlike the repealed law, SB 26-189 does not require impact assessments — obligations are pre-use notice, a 30-day plain-language disclosure after an adverse consequential decision, and 3-year recordkeeping.

Timeline

Original Colorado AI Act (SB 24-205) signed into law

May 17, 2024

SB 24-205 repealed and replaced by SB 26-189 (ADMT law), signed by Gov. Polis

May 14, 2026

TODAY

September 9, 2026

SB 26-189 takes effect — notice, disclosure, and recordkeeping duties begin

January 1, 2027

First 30-day adverse-outcome disclosures come due for decisions made on/after Jan 1

January 31, 2027

What happens if you don't comply

SB 26-189 is enforced exclusively by the Colorado Attorney General under the Colorado Consumer Protection Act — there is no private right of action. Maximum civil penalty is $20,000 per violation (C.R.S. § 6-1-112(1)(a)). The AG must issue a notice of violation and an opportunity to cure before enforcing, where the AG deems the violation curable. Businesses that do not post the required pre-use ADMT notice, do not provide the 30-day adverse-outcome disclosure, or do not retain compliance records face enforcement action.

Who is affected

Businesses doing business in Colorado that use a covered ADMT — technology that processes personal data and uses computation to materially influence a "consequential decision" about a Colorado resident's access to, eligibility for, or terms of employment, credit/lending, education, healthcare/insurance, or housing/public accommodation — even if they did not build the tool themselves. Developers who build, modify, or substantially modify covered ADMT have a separate disclosure duty to their deployer customers.

What to do right now

1

Inventory every ADMT that processes personal data and produces scores, rankings, recommendations, or classifications used in consequential decisions about Colorado residents

2

Confirm whether each tool "materially influences" a consequential decision — not every AI-assisted process is in scope

3

Publish a prominent pre-use ADMT notice at points of consumer interaction (e.g., near the application or transaction)

4

Build the 30-day adverse-outcome disclosure process: plain-language decision description, ADMT name/version/developer, and data-category summary

5

Set up a compliance-record retention process — records must be kept at least 3 years after each consequential decision

6

If you sell or license ADMT to others: prepare the developer-side disclosure of training data categories and known limitations

Related Deadlines