From the journal

Colorado Enacts Automated Decision-Making Technology Law, Replacing 2024 AI Act, May 2026

Colorado Governor Jared Polis signed SB 26-189 into law on May 14, 2026, repealing and replacing the original Colorado AI Act (SB 24-205). The new law regulates automated decision-making technology in consequential decisions, requiring deployers to conduct impact assessments, disclose ADMT use to affected individuals, and provide opt-out rights. The Act takes effect July 1, 2026.

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On May 14, 2026, Colorado Governor Jared Polis signed SB 26-189, Automated Decision-Making Technology, into law. The Act repeals and reenacts the consumer AI protections first passed in SB 24-205, the 2024 Colorado AI Act. SB 26-189 is final enacted law and takes effect July 1, 2026.

SB 26-189 is codified in Title 6, Colorado Revised Statutes. Section 2 defines 'automated decision-making technology' (ADMT) as any technology that processes personal data and uses computation to produce output, including predictions, recommendations, classifications, rankings, or scores used to make, guide, or assist a consequential decision. Section 3 defines consequential decisions as determinations materially affecting employment, education, housing, credit, healthcare, or insurance.

ADMT deployers must conduct and retain algorithmic impact assessments before deployment, provide clear pre-deployment notice to individuals subject to consequential decisions, and offer a meaningful opt-out mechanism. Developers must supply deployers with technical documentation sufficient to enable those assessments. The Colorado Attorney General enforces the Act; violations expose both developers and deployers to civil penalties.

SB 26-189 applies a tiered risk structure, with heightened obligations attaching to ADMT presenting elevated risk. Businesses below a statutory size threshold are exempt. The Act supersedes the February 1, 2026 effective date of SB 24-205 and replaces that statute entirely.

Licentium advises clients on AI compliance across U.S. state laws and international regulatory programs. We assist with ADMT inventory mapping, impact assessment design, and disclosure program development. Work we undertake includes AI governance advisory, U.S. state AI law compliance, regulatory impact assessments, and cross-border AI regulatory mapping.

Source: Colorado General Assembly, SB 26-189 Automated Decision-Making Technology, signed 14 May 2026

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