Colorado AI Act repealed: what SB 26-189 requires from 2027
Colorado's 2024 AI Act never took effect. SB 26-189 replaces it from 1 January 2027 with narrower duties: notice, adverse-decision disclosure, human review, records and developer documentation.
What happened on 14 May 2026
The Governor signed SB 26-189, which repeals and re-enacts the Colorado AI Act (SB 24-205) before its delayed 30 June 2026 effective date. SB 24-205 never took effect. Both records are pending review: they were recorded from secondary reporting, so confirm the details against the enrolled bill.
What was dropped
The replacement drops SB 24-205's duty of reasonable care, the impact assessments, the risk-management programme and the Attorney General notification. If you were building to those requirements, stop and re-scope to the new duties.
Who is covered
SB 26-189 attaches duties when automated decision-making technology materially influences a consequential decision about a Colorado consumer, in areas such as employment, lending, housing, education, healthcare, insurance and government services.
Before the decision: notice
Deployers must notify consumers before the technology influences a consequential decision about them.
After an adverse decision: disclosure and human review
After an adverse consequential decision, disclose that the technology was used and the principal reasons, and offer meaningful human review of the decision.
Records and developer documentation
Keep records of consequential decisions influenced by the technology for three years. Developers must give deployers documentation of the technology so that deployers can meet their own duties.
Plan for 1 January 2027
Inventory the decisions your systems influence in Colorado, draft the notices and adverse-decision letters, design the human-review route, and agree documentation terms with your vendors before the law applies.
Obligations referenced in this guide
- Legal Notify consumers before automated decision-making technology influences a consequential decision (Colorado ADMT law (SB 26-189), Colorado (United States))
- Legal Disclose the use of the technology and the principal reasons after an adverse consequential decision (Colorado ADMT law (SB 26-189), Colorado (United States))
- Legal Developers must supply deployers with documentation of the technology (Colorado ADMT law (SB 26-189), Colorado (United States))
- Legal Offer meaningful human review of an adverse consequential decision (Colorado ADMT law (SB 26-189), Colorado (United States))
- Legal Keep records of consequential decisions influenced by the technology for three years (Colorado ADMT law (SB 26-189), Colorado (United States))
Frequently asked questions
Is the Colorado AI Act repealed?
Yes, according to the record: SB 26-189, signed on 14 May 2026, repeals and re-enacts the Colorado AI Act (SB 24-205) before it took effect. The record is pending review against the enrolled bill.
When does Colorado SB 26-189 apply?
From 1 January 2027, according to the record.
Do I still need a Colorado AI impact assessment?
Not under SB 26-189 as recorded: the replacement law drops the impact assessments, the risk-management programme and the duty of care that SB 24-205 would have imposed.
What counts as a consequential decision?
A decision with a material effect on a consumer in areas such as employment, lending, housing, education, healthcare, insurance and government services. Check the definition in the enrolled bill for your case.
Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.