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Colorado Governor Signs SB 26-189 Replacing Consumer AI Act with ADMT Rules, May 2026

Colorado Governor Jared Polis signed Senate Bill 26-189 into law on May 14, 2026. The Act repeals Senate Bill 24-205 from 2024 and establishes new obligations for developers and deployers of automated decision-making technology in consequential decisions, shifting from a broad algorithmic accountability regime to a targeted transparency and consumer rights framework.

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Colorado Governor Jared Polis signed Senate Bill 26-189 into law on May 14, 2026. The Act is effective upon signature and repeals and replaces the Colorado AI Act (SB 24-205) enacted in 2024. SB 26-189 establishes a revised regulatory regime for automated decision-making technology (ADMT) in Colorado. The law applies to developers and deployers of ADMT used in consequential decisions affecting Colorado residents.

SB 26-189 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, that guides or assists a consequential decision. The Act repeals the prior high-risk AI framework under SB 24-205 in its entirety. Rulemaking authority under the new Act rests with the Colorado Attorney General.

Developers of ADMT used in consequential decisions must conduct impact assessments and provide disclosures to consumers. Deployers must inform affected Colorado residents when ADMT drives a consequential decision. Employers using ADMT in hiring, performance evaluation, or termination decisions face new notice obligations under the Act. Health care providers using ADMT in clinical determinations also fall within the statutory scope.

The new law narrows scope from SB 24-205's broad high-risk AI accountability regime to a more targeted transparency framework focused on consequential decisions. SB 24-205 provisions regarding high-risk AI systems are repealed as of the Act's effective date. Pending questions include the Attorney General's rulemaking timeline and how the Act's definitions interact with federal AI governance proposals currently advancing through Congress.

Licentium advises on AI regulatory compliance across US state jurisdictions and may assist companies assessing obligations under SB 26-189. Please contact us to discuss your situation. Work we undertake includes AI governance program design, state AI law compliance analysis, ADMT classification assessment, consumer disclosure framework drafting, and regulatory filing support.

Source: Colorado General Assembly, Senate Bill 26-189 Automated Decision-Making Technology, signed 14 May 2026, https://leg.colorado.gov/bills/sb26-189

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

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