From the journal

Colorado Enacts ADMT Law for Consequential Decisions, May 2026

Colorado enacted SB26-189 on 14 May 2026, replacing its 2024 AI consumer protection law with automated decision-making technology rules. From 1 January 2027, covered developers and deployers must support documentation, consumer notices, post-adverse outcome explanations, data access, correction, and human review rights.

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Colorado enacted SB26-189 on 14 May 2026. The act repeals and reenacts Colorado AI consumer protection provisions for automated decision-making technology used in consequential decisions.

The controlling instrument is SB26-189, enforced through the Colorado Consumer Protection Act. It defines ADMT, covered ADMT, and consequential decisions. From 1 January 2027, developers must provide technical documentation to deployers. Deployers must give clear consumer notices and post-adverse outcome explanations.

Developers of covered systems must document intended uses, training data categories, known limits, and human review instructions. Deployers in employment, housing, lending, insurance, health care, education, and public benefits must prepare notice, review, correction, and record-retention processes.

The act requires the Attorney General to adopt rules on post-adverse outcome disclosures by 1 January 2027. It creates no new private right of action. Before 1 January 2030, the Attorney General must give 60 days notice and an opportunity to cure where cure is possible.

Licentium may advise developers, deployers, and regulated buyers on ADMT governance directly or through partner counsel. Work we undertake includes AI Regulatory, product governance, technical documentation, consumer notice design, vendor allocation, and enforcement response.

Source: Colorado General Assembly, SB26-189 Automated Decision-Making Technology, signed 14 May 2026.

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