On 11 August 2026, the Colorado Department of Law (DOL) filed proposed rules implementing two 2026 Colorado statutes: the Automated Decision-Making Technology Act (ADMT Act) and the Conversational Artificial Intelligence Service Operator Requirements Act (Chatbot Safety Act). Both statutes take effect 1 January 2027; the proposed rules carry the same effective date. The DOL opened a formal comment period through 26 October 2026, preferring submissions by 5 October 2026 to allow consideration before the rulemaking hearing.
Under the ADMT Act and its proposed rules, developers and deployers of automated decision-making technology must give consumers pre-decision notices before any consequential decision affecting employment, housing, credit, education, or healthcare access is made by or substantially assisted by an automated system. The rules define the scope of 'consequential decision' and 'automated decision-making technology,' set notice timing and content requirements, and establish consumer opt-out and appeal rights. Under the Chatbot Safety Act, operators of conversational AI services must disclose to all users that they are interacting with AI rather than a human; for minor users, a persistent visible disclaimer is required throughout the interaction.
Technology companies, AI platform developers, healthcare systems, financial institutions, employers, and educational institutions operating in Colorado must determine whether their automated decision tools fall within the ADMT Act's scope. Consumer-facing conversational AI operators, including customer service bots, AI tutors, and health-information assistants, must build disclosure interfaces that meet the proposed rules' format and timing requirements before 1 January 2027. Both developer and deployer obligations arise under the rules; commercial agreements between AI vendors and deploying businesses may need revision to allocate compliance duties.
The proposed rules impose age-assurance obligations on chatbot operators serving minor users and prohibit specified content types and interaction patterns in AI services accessible to minors. Annual reporting duties apply to in-scope chatbot operators. The DOL has not published a final regulatory impact assessment. The interaction between the ADMT Act and Colorado's Consumer Protection Act, and the potential displacement of existing state agency guidance, remain open questions for the final rulemaking.
We may advise on US state AI regulatory compliance and can introduce clients to specialists in our partner network. Contact us to discuss compliance with ADMT-style laws in Colorado and other US jurisdictions. Work we undertake includes AI regulatory mapping, ADMT compliance assessments, automated decision system audits, consumer disclosure design, and AI vendor contract review.