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Fast Take

Colorado AI Act: SB26-189 (ADMT Act) Replaces SB 24-205 — New January 1, 2027 Deadline

AI Laws by State Updated May 17, 2026 6 min read
Enacted (Amended) — Effective January 1, 2027
⚠️ Important update — May 14, 2026 On May 14, 2026, Colorado Governor Jared Polis signed SB26-189, which repealed and replaced SB 24-205. The amended law — now the Colorado Automated Decision-Making Technology (ADMT) Act — takes effect January 1, 2027. The algorithmic-discrimination duty of care, mandatory impact assessments, and the risk-management program requirement have been removed. See our updated SB26-189 compliance guide.

What It Does (As Amended)

Colorado SB 24-205, the original Colorado Artificial Intelligence Act, was repealed and replaced by SB26-189 on May 14, 2026. The amended law is now the Colorado Automated Decision-Making Technology (ADMT) Act, taking effect January 1, 2027. The amended Act requires developers to provide deployers with technical documentation, requires deployers to give clear and conspicuous notice at the point of interaction and a plain-language description within 30 days of any adverse consequential decision, and gives consumers the right to correct data and request meaningful human review. The Colorado Attorney General has exclusive enforcement authority.

Who It Applies To

The amended law applies to two categories: developers (entities that design, code, or substantially modify ADMT) and deployers (entities that use ADMT to make or materially influence consequential decisions). Consequential decisions cover seven domains under SB26-189: education, employment, housing, financial or lending services, insurance, healthcare, and essential government services. SB26-189 also clarifies that the Act does not apply to independent contractors or non-Colorado residents, and applies only to employers “doing business in Colorado.”

Key Provisions (Updated for SB26-189)

Compliance Checklist

If you develop or deploy ADMT affecting Colorado consumers, before January 1, 2027 you should:

  1. Classify your ADMT systems to determine which make or materially influence consequential decisions.
  2. Build a point-of-interaction notice wherever ADMT is used in consequential decisions.
  3. Build an adverse-outcome disclosure workflow able to deliver a plain-language description within 30 days. Watch for the Colorado AG’s rulemaking due by Jan 1, 2027.
  4. Build consumer-rights workflows to correct personal data and route adverse-outcome appeals to meaningful human review.
  5. If you are a developer: Prepare technical documentation packages for deployers covering intended use, training data categories, known limitations, and consequential-decision use cases.
  6. Set 3-year record retention for documentation, notices, and human-review records.
  7. Evaluate governance tooling: The AI Compliance Vendors directory profiles platforms supporting ADMT documentation, consumer-notice workflows, and adverse-outcome disclosures.

How This Compares

Colorado’s ADMT Act remains one of the broadest state AI laws in the U.S. as of June 2026, but is now narrower than the original SB 24-205. It goes further than NYC Local Law 144, which covers only hiring AI. It is more focused on documentation and consumer notice than the EU AI Act’s risk-based framework. The amendments also reflect federal preemption pressure — see our federal AI preemption guide covering the December 2025 executive order and the DOJ’s April 2026 intervention in xAI v. Colorado.

Effective Date Countdown

Compliance deadline: January 1, 2027. Companies preparing for the original June 30, 2026 deadline should pause work tied to the removed obligations (algorithmic-discrimination duty of care, impact assessments, NIST AI RMF program) and redirect to ADMT documentation, point-of-interaction notice, adverse-outcome disclosure within 30 days, and consumer-rights workflows.

Read the Bill


Author: AI Laws by State. This is not legal advice. For compliance questions specific to your operation, consult an attorney licensed in Colorado.

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Sources & References

All claims are sourced from primary government, academic, and standards-body materials. Found something we got wrong? Submit a correction.

  1. National Conference of State Legislatures — Artificial Intelligence in the States — nonpartisan aggregator of state AI legislation
  2. NIST AI Risk Management Framework (AI RMF 1.0) — federal standard referenced by many state AI laws
  3. Federal Trade Commission — AI and Consumer Protection — federal consumer protection guidance on AI disclosures
  4. LegiScan — Bill Tracking and Aggregation — nonpartisan legislative tracking database
  5. Congress.gov — federal legislation and committee reports — official federal legislative information

See our methodology for how we source, verify, and update this content.