Colorado ADMT law (SB 26-189): requirements, deadlines and compliance actions
Colorado Senate Bill 26-189: Automated Decision-Making Technology (replacement of the Colorado AI Act)
In brief
The Colorado ADMT law (SB 26-189) is a binding act of Colorado (United States), issued by Colorado General Assembly. It was adopted on 14 May 2026 and applies from 1 January 2027. Applies to developers and deployers of automated decision-making technology used to make, or to materially influence, consequential decisions about Colorado residents.
- Jurisdiction
- Colorado (United States)
- Instrument type
- Act / statute
- Status
- Adopted
- Legal force
- Binding
- Issuing body
- Colorado General Assembly
- Adopted
- 14 May 2026
- Published
- 14 May 2026
- Applies from
- 1 January 2027
- Obligations recorded
- 5
- Source reference
- SB 26-189 (2026 regular session)
- Official source
- SB26-189 Automated Decision-Making Technology
- Verification
- Source-linked · checked 26 Sep 2026
What is the Colorado ADMT law (SB 26-189)?
SB 26-189 replaces the Colorado AI Act's regulation of "high-risk" AI systems with duties that attach 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. It drops the earlier duty of reasonable care, the mandatory risk-management programme, impact assessments and Attorney General notification, and substitutes advance notice to the consumer, disclosure after an adverse outcome, meaningful human review, three-year record keeping and developer documentation obligations.
Status note: Signed by the Governor on 14 May 2026 and, according to concordant secondary reporting, applies to consequential decisions made on or after 1 January 2027. It repeals and re-enacts the framework of SB 24-205 (the Colorado AI Act) with a narrower scope built around "automated decision-making technology". Recorded on 26 September 2026 from law-firm summaries; the enrolled bill on the Colorado General Assembly site has not yet been read by a reviewer here, so every date and duty below is pending review.
Who does it apply to?
Applies to developers and deployers of automated decision-making technology used to make, or to materially influence, consequential decisions about Colorado residents. Exemptions and thresholds follow the enrolled bill, which a reviewer must read; secondary reporting describes exemptions for certain regulated financial institutions and federally approved systems. Enforcement is by the Colorado Attorney General.
Developers and deployers of automated decision-making technology that materially influences consequential decisions about Colorado residents.
- Sectors
- Employment and HRFinancial services and creditHealthcare and life sciencesEducation and trainingPublic services and government
- AI use cases
- AI in hiring and employmentAI in healthcareAI in finance, credit and insuranceAI in educationAI in public services
- Risk categories
- High-risk
- AI system types
- Automated decision-making systemPredictive or scoring system
When do the requirements apply?
Signed 14 May 2026; applies to consequential decisions made on or after 1 January 2027 (pending review against the enrolled bill).
| Date | Milestone | Source reference | Status |
|---|---|---|---|
| Signed into law Governor signed SB 26-189 (secondary reporting; confirm against the bill history). |
— | Passed confidence: medium |
|
| Applies to consequential decisions made on or after this date Effective date per secondary reporting on the enrolled bill; confirm on the Colorado General Assembly site. |
— | Scheduled confidence: medium |
Effective date and the "consequential decisions made on or after" formulation come from secondary reporting on the enrolled bill; confirm on the Colorado General Assembly site.
What must organisations do?
Inventory the automated tools that influence consequential decisions about Colorado residents; give consumers notice before such a tool is used; when an outcome is adverse, tell the consumer that the technology was used, the principal reasons, and how to seek meaningful human review; keep records of those decisions for three years; and, as a developer, supply deployers with the documentation the statute lists.
Legal requirement Notify consumers before automated decision-making technology influences a consequential decision
Deployers must tell a consumer, before the decision is made, that automated decision-making technology will be used to make or materially influence a consequential decision about them. The exact content and timing of the notice follow the enrolled bill, which a reviewer must read.
Practical action: Add a plain-language notice to every consumer-facing flow in which an automated tool influences a consequential decision.
Obligation pageApplies from 1 Jan 2027 Source-linked (a factual check against the official source, not a legal review or legal advice)
Legal requirement Disclose the use of the technology and the principal reasons after an adverse consequential decision
After an adverse consequential decision, the deployer must tell the consumer that automated decision-making technology was used, give the principal reasons for the decision, and explain how to obtain human review.
Practical action: Template an adverse-decision letter that names the tool, the main reasons and the human-review route.
Obligation pageApplies from 1 Jan 2027 Source-linked (a factual check against the official source, not a legal review or legal advice)
Legal requirement Offer meaningful human review of an adverse consequential decision
A consumer who receives an adverse consequential decision may obtain meaningful review by a person with the authority and information to change the outcome. Scope and timing follow the enrolled bill.
Practical action: Staff and document a human-review channel with authority to reverse decisions.
Obligation pageApplies from 1 Jan 2027 Source-linked (a factual check against the official source, not a legal review or legal advice)
Legal requirement Keep records of consequential decisions influenced by the technology for three years
Deployers must retain records showing how automated decision-making technology was used in consequential decisions, for three years, according to secondary reporting on the enrolled bill.
Practical action: Log each decision, the tool used, inputs relied on and the notices sent, with a three-year retention rule.
Obligation pageApplies from 1 Jan 2027 Source-linked (a factual check against the official source, not a legal review or legal advice)
Legal requirement Developers must supply deployers with documentation of the technology
Developers of automated decision-making technology must provide deployers with the documentation the statute lists, so that deployers can meet their notice, disclosure and review duties.
Practical action: Publish a deployer-facing documentation pack for each tool sold into consequential-decision uses.
Obligation pageApplies from 1 Jan 2027 Source-linked (a factual check against the official source, not a legal review or legal advice)
Penalties
Enforcement by the Colorado Attorney General under the Colorado Consumer Protection Act, according to secondary reporting, with no private right of action. Confirm the enforcement provisions against the enrolled bill.
Key sections and articles
| Reference | Title | Summary |
|---|---|---|
| Advance notice | Notice before use | Consumers are told before automated decision-making technology is used in a consequential decision. |
| Adverse outcomes | Disclosure after an adverse decision | Reasons, the role of the technology and a route to human review after an adverse consequential decision. |
| Records | Record keeping | Records of consequential decisions influenced by the technology are kept for three years. |
| Developers | Developer documentation | Developers supply deployers with the documentation the statute lists. |
Official sources
-
SB26-189 Automated Decision-Making Technology
Colorado General Assembly · 14 May 2026 · Tier 1 source
Cite this record
AIPolicyTracker (2026). “Colorado ADMT law (SB 26-189)”. https://aipolicytracker.org/policies/us-colorado-automated-decision-making-technology-act (accessed 27 September 2026). Data licensed CC BY 4.0.
Cite the official text alongside it: SB26-189 Automated Decision-Making Technology, Colorado General Assembly, https://leg.colorado.gov/bills/sb26-189.
Change history
- — Colorado repeals and replaces its AI Act with SB 26-189, effective 1 January 2027
- 14 May 2026 — Enrolled bill SB 26-189, signed 14 May 2026 (source)
All updates for Colorado · RSS · Updates hub
Record version 1: New record from secondary reporting on the signed bill; pending review against the enrolled text.. Full edit history is in the GitHub repository.
Frequently asked questions
- When does Colorado's SB 26-189 apply?
- To consequential decisions made on or after 1 January 2027, according to secondary reporting on the enrolled bill signed on 14 May 2026. Confirm on the Colorado General Assembly site before relying on the date.
- What happened to the Colorado AI Act (SB 24-205)?
- SB 26-189 repealed and re-enacted it before its delayed 30 June 2026 effective date, replacing the duty of care, impact assessments and risk-management programme with notice, disclosure, human-review, record-keeping and developer-documentation duties.
- Is the Colorado ADMT law (SB 26-189) in force?
- Not yet. The Colorado ADMT law (SB 26-189) has been adopted (14 May 2026) and applies from 1 January 2027.
- Is the Colorado ADMT law (SB 26-189) legally binding?
- Yes. The Colorado ADMT law (SB 26-189) is a binding act / statute; the obligations it creates are legal requirements for the actors it covers.
- Who does the Colorado ADMT law (SB 26-189) apply to?
- Applies to developers and deployers of automated decision-making technology used to make, or to materially influence, consequential decisions about Colorado residents. Exemptions and thresholds follow the enrolled bill, which a reviewer must read; secondary reporting describes exemptions for certain regulated financial institutions and federally approved systems. Enforcement is by the Colorado Attorney General.
- When does the Colorado ADMT law (SB 26-189) apply?
- Signed 14 May 2026; applies to consequential decisions made on or after 1 January 2027 (pending review against the enrolled bill).
- What must organisations do under the Colorado ADMT law (SB 26-189)?
- Inventory the automated tools that influence consequential decisions about Colorado residents; give consumers notice before such a tool is used; when an outcome is adverse, tell the consumer that the technology was used, the principal reasons, and how to seek meaningful human review; keep records of those decisions for three years; and, as a developer, supply deployers with the documentation the statute lists.
- What are the penalties under the Colorado ADMT law (SB 26-189)?
- Enforcement by the Colorado Attorney General under the Colorado Consumer Protection Act, according to secondary reporting, with no private right of action. Confirm the enforcement provisions against the enrolled bill.
- Where is the official text of the Colorado ADMT law (SB 26-189)?
- The official text is published by Colorado General Assembly at https://leg.colorado.gov/bills/sb26-189 (SB26-189 Automated Decision-Making Technology). This record links to it and is checked against it.
Informational only, not legal advice. Verify every claim against the linked official sources and consult qualified counsel before acting.
Frequently asked questions
- When does Colorado's SB 26-189 apply?
- To consequential decisions made on or after 1 January 2027, according to secondary reporting on the enrolled bill signed on 14 May 2026. Confirm on the Colorado General Assembly site before relying on the date.
- What happened to the Colorado AI Act (SB 24-205)?
- SB 26-189 repealed and re-enacted it before its delayed 30 June 2026 effective date, replacing the duty of care, impact assessments and risk-management programme with notice, disclosure, human-review, record-keeping and developer-documentation duties.
- Is the Colorado ADMT law (SB 26-189) in force?
- Not yet. The Colorado ADMT law (SB 26-189) has been adopted (14 May 2026) and applies from 1 January 2027.
- Is the Colorado ADMT law (SB 26-189) legally binding?
- Yes. The Colorado ADMT law (SB 26-189) is a binding act / statute; the obligations it creates are legal requirements for the actors it covers.
- Who does the Colorado ADMT law (SB 26-189) apply to?
- Applies to developers and deployers of automated decision-making technology used to make, or to materially influence, consequential decisions about Colorado residents. Exemptions and thresholds follow the enrolled bill, which a reviewer must read; secondary reporting describes exemptions for certain regulated financial institutions and federally approved systems. Enforcement is by the Colorado Attorney General.
- When does the Colorado ADMT law (SB 26-189) apply?
- Signed 14 May 2026; applies to consequential decisions made on or after 1 January 2027 (pending review against the enrolled bill).
- What must organisations do under the Colorado ADMT law (SB 26-189)?
- Inventory the automated tools that influence consequential decisions about Colorado residents; give consumers notice before such a tool is used; when an outcome is adverse, tell the consumer that the technology was used, the principal reasons, and how to seek meaningful human review; keep records of those decisions for three years; and, as a developer, supply deployers with the documentation the statute lists.
- What are the penalties under the Colorado ADMT law (SB 26-189)?
- Enforcement by the Colorado Attorney General under the Colorado Consumer Protection Act, according to secondary reporting, with no private right of action. Confirm the enforcement provisions against the enrolled bill.
- Where is the official text of the Colorado ADMT law (SB 26-189)?
- The official text is published by Colorado General Assembly at https://leg.colorado.gov/bills/sb26-189 (SB26-189 Automated Decision-Making Technology). This record links to it and is checked against it.