{"slug":"us-colorado-automated-decision-making-technology-act","title":"Colorado Senate Bill 26-189: Automated Decision-Making Technology (replacement of the Colorado AI Act)","short_title":"Colorado ADMT law (SB 26-189)","jurisdiction":"us-colorado","instrument_type":"act","status":"adopted","is_binding":true,"issuing_body":"Colorado General Assembly","summary_plain":"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.\n","adopted_on":"2026-05-14","in_force_on":null,"applies_from":"2027-01-01","official_source_url":"https://leg.colorado.gov/bills/sb26-189","last_verified_at":null,"review_status":"pending_review","confidence_level":"medium","updated_at":"2026-09-27T02:30:02+00:00","url":"https://aipolicytracker.org/policies/us-colorado-automated-decision-making-technology-act","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.\n","scope_summary":"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.\n","who_it_applies_to":"Developers and deployers of automated decision-making technology that materially influences consequential decisions about Colorado residents.","key_dates_summary":"Signed 14 May 2026; applies to consequential decisions made on or after 1 January 2027 (pending review against the enrolled bill).","penalties_summary":"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.\n","what_organizations_must_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.\n","published_on":"2026-05-14","date_notes":"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.","taxonomy":{"actor":["provider","deployer"],"ai_system_type":["automated_decision_system","predictive_scoring"],"sector":["employment","financial_services","healthcare","education","public_services"],"risk_category":["high_risk"],"use_case":["hiring_and_hr","health","finance_and_credit","education","public_services"]},"sections":[{"reference":"Advance notice","title":"Notice before use","summary":"Consumers are told before automated decision-making technology is used in a consequential decision.","official_source_url":null},{"reference":"Adverse outcomes","title":"Disclosure after an adverse decision","summary":"Reasons, the role of the technology and a route to human review after an adverse consequential decision.","official_source_url":null},{"reference":"Records","title":"Record keeping","summary":"Records of consequential decisions influenced by the technology are kept for three years.","official_source_url":null},{"reference":"Developers","title":"Developer documentation","summary":"Developers supply deployers with the documentation the statute lists.","official_source_url":null}],"obligations":[{"slug":"us-colorado-admt-advance-notice","title":"Notify consumers before automated decision-making technology influences a consequential decision","category":"transparency","summary":"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.\n","practical_action":"Add a plain-language notice to every consumer-facing flow in which an automated tool influences a consequential decision.","is_binding":true,"applies_from":"2027-01-01","section":"Advance notice","source_reference":null,"official_source_url":"https://leg.colorado.gov/bills/sb26-189","review_status":"pending_review","confidence_level":"medium","last_verified_at":null,"actors":["deployer"],"sectors":["employment","financial_services","healthcare","education","public_services"],"use_cases":["hiring_and_hr","finance_and_credit","health","education","public_services"],"applicability":[],"evidence_examples":[],"framework_mappings":[],"controls":[{"slug":"ai-interaction-and-use-disclosure","title":"AI interaction and use disclosure notices","kind":"process","relationship":"satisfies","note":"Pre-decision notice that an automated tool will influence the decision.","confidence_level":"high","url":"https://aipolicytracker.org/controls/ai-interaction-and-use-disclosure"}],"url":"https://aipolicytracker.org/obligations/us-colorado-admt-advance-notice"},{"slug":"us-colorado-admt-adverse-decision-disclosure","title":"Disclose the use of the technology and the principal reasons after an adverse consequential decision","category":"transparency","summary":"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.\n","practical_action":"Template an adverse-decision letter that names the tool, the main reasons and the human-review route.","is_binding":true,"applies_from":"2027-01-01","section":"Adverse outcomes","source_reference":null,"official_source_url":"https://leg.colorado.gov/bills/sb26-189","review_status":"pending_review","confidence_level":"medium","last_verified_at":null,"actors":["deployer"],"sectors":["employment","financial_services","healthcare","education","public_services"],"use_cases":["hiring_and_hr","finance_and_credit","health","education","public_services"],"applicability":[],"evidence_examples":[],"framework_mappings":[],"controls":[{"slug":"decision-explanation-and-appeal-route","title":"Decision explanation, human review and appeal route","kind":"process","relationship":"satisfies","note":"Adverse-decision reasons, the role of the tool and the review route.","confidence_level":"high","url":"https://aipolicytracker.org/controls/decision-explanation-and-appeal-route"}],"url":"https://aipolicytracker.org/obligations/us-colorado-admt-adverse-decision-disclosure"},{"slug":"us-colorado-admt-human-review","title":"Offer meaningful human review of an adverse consequential decision","category":"human_oversight","summary":"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.\n","practical_action":"Staff and document a human-review channel with authority to reverse decisions.","is_binding":true,"applies_from":"2027-01-01","section":"Adverse outcomes","source_reference":null,"official_source_url":"https://leg.colorado.gov/bills/sb26-189","review_status":"pending_review","confidence_level":"medium","last_verified_at":null,"actors":["deployer"],"sectors":["employment","financial_services","healthcare","education","public_services"],"use_cases":["hiring_and_hr","finance_and_credit","health","education","public_services"],"applicability":[],"evidence_examples":[],"framework_mappings":[],"controls":[{"slug":"decision-explanation-and-appeal-route","title":"Decision explanation, human review and appeal route","kind":"process","relationship":"supports","note":"The request channel that leads to review.","confidence_level":"medium","url":"https://aipolicytracker.org/controls/decision-explanation-and-appeal-route"},{"slug":"human-oversight-and-override","title":"Human oversight design and override procedure","kind":"process","relationship":"satisfies","note":"A reviewer with authority to change the outcome.","confidence_level":"high","url":"https://aipolicytracker.org/controls/human-oversight-and-override"}],"url":"https://aipolicytracker.org/obligations/us-colorado-admt-human-review"},{"slug":"us-colorado-admt-record-keeping","title":"Keep records of consequential decisions influenced by the technology for three years","category":"record_keeping","summary":"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.\n","practical_action":"Log each decision, the tool used, inputs relied on and the notices sent, with a three-year retention rule.","is_binding":true,"applies_from":"2027-01-01","section":"Records","source_reference":null,"official_source_url":"https://leg.colorado.gov/bills/sb26-189","review_status":"pending_review","confidence_level":"medium","last_verified_at":null,"actors":["deployer"],"sectors":["employment","financial_services","healthcare","education","public_services"],"use_cases":["hiring_and_hr","finance_and_credit","health","education","public_services"],"applicability":[],"evidence_examples":[],"framework_mappings":[],"controls":[{"slug":"record-keeping-and-logging","title":"Automatic event logging and record retention","kind":"technical","relationship":"satisfies","note":"Decision records retained for the statutory period.","confidence_level":"high","url":"https://aipolicytracker.org/controls/record-keeping-and-logging"}],"url":"https://aipolicytracker.org/obligations/us-colorado-admt-record-keeping"},{"slug":"us-colorado-admt-developer-documentation","title":"Developers must supply deployers with documentation of the technology","category":"technical_documentation","summary":"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.\n","practical_action":"Publish a deployer-facing documentation pack for each tool sold into consequential-decision uses.","is_binding":true,"applies_from":"2027-01-01","section":"Developers","source_reference":null,"official_source_url":"https://leg.colorado.gov/bills/sb26-189","review_status":"pending_review","confidence_level":"medium","last_verified_at":null,"actors":["provider"],"sectors":["employment","financial_services","healthcare","education","public_services"],"use_cases":["hiring_and_hr","finance_and_credit","health","education","public_services"],"applicability":[],"evidence_examples":[],"framework_mappings":[],"controls":[{"slug":"contractual-allocation-of-ai-duties","title":"Contractual allocation of AI duties across the supply chain","kind":"contractual","relationship":"supports","note":"Contract terms that deliver the documentation to deployers.","confidence_level":"medium","url":"https://aipolicytracker.org/controls/contractual-allocation-of-ai-duties"},{"slug":"technical-documentation-and-model-cards","title":"Technical documentation, model cards and instructions for use","kind":"process","relationship":"satisfies","note":"Deployer-facing documentation of each tool.","confidence_level":"high","url":"https://aipolicytracker.org/controls/technical-documentation-and-model-cards"}],"url":"https://aipolicytracker.org/obligations/us-colorado-admt-developer-documentation"}],"applicability_rules":[],"deadlines":[{"title":"Signed into law","due_on":"2026-05-14","date_precision":"exact","date_label":null,"display_date":"14 May 2026","description":"Governor signed SB 26-189 (secondary reporting; confirm against the bill history).","source_reference":null,"official_source_url":null,"status":"passed","confidence_level":"medium"},{"title":"Applies to consequential decisions made on or after this date","due_on":"2027-01-01","date_precision":"exact","date_label":null,"display_date":"1 January 2027","description":"Effective date per secondary reporting on the enrolled bill; confirm on the Colorado General Assembly site.","source_reference":null,"official_source_url":null,"status":"scheduled","confidence_level":"medium"}],"versions":[{"version_label":"Enrolled bill SB 26-189, signed 14 May 2026","version_date":"2026-05-14","summary":"Repeals and re-enacts the Colorado AI Act framework as an automated-decision-making-technology law; pending review against the enrolled text.","official_source_url":"https://leg.colorado.gov/bills/sb26-189","source_reference":"SB 26-189"}],"enforcement_events":[],"procurement_rules":[],"sources":[{"title":"SB26-189 Automated Decision-Making Technology","publisher":"Colorado General Assembly","url":"https://leg.colorado.gov/bills/sb26-189","document_date":"2026-05-14","document_type":"legislation","tier":1,"tier_label":"Official primary source (government, legislature, regulator, court, standards body, intergovernmental)"}],"related_policies":["us-colorado-ai-act","us-nist-ai-rmf","eu-ai-act"],"related_frameworks":["nist_ai_rmf","iso_42001"],"faq":[{"question":"When does Colorado's SB 26-189 apply?","answer":"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.\n"},{"question":"What happened to the Colorado AI Act (SB 24-205)?","answer":"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.\n"}],"source":{"official_source_url":"https://leg.colorado.gov/bills/sb26-189","source_title":"SB26-189 Automated Decision-Making Technology","source_publisher":"Colorado General Assembly","source_document_date":"2026-05-14","source_reference":"SB 26-189 (2026 regular session)","source_tier":1,"last_checked_at":"2026-09-26","last_verified_at":null,"review_status":"pending_review","confidence_level":"medium","content_version":1,"change_summary":"New record from secondary reporting on the signed bill; pending review against the enrolled text.","reviewed_by":null}}