Colorado ADMT ActUpcomingUnited States · Colorado

Colorado Automated Decision-Making Technology Act (SB 26-189, replacing SB 24-205)

Last reviewed Sep 25, 2026.

In short

Colorado repealed its landmark 2024 AI Act before it ever applied and replaced it with SB 26-189, effective 1 January 2027. The new law drops the duty-of-care and annual impact-assessment model and instead focuses on transparency: deployers must give notice before a covered ADMT influences a consequential decision, explain adverse decisions within 30 days, and let people correct data and request human review. Developers must give deployers documentation on intended use, training-data categories, limits and human-review instructions. The Attorney General enforces it exclusively.

Who it applies to

Organisations that build or use AI systems in United States · Colorado.
Use cases in scope: hiring & HR, credit & lending, insurance, healthcare, education, legal, public sector, profiling & scoring.
Size: everyone, including solo operators.
Covers 'automated decision-making technology' that processes personal data and materially influences a consequential decision in education, employment, housing, lending, insurance, healthcare or essential government services. Advertising, content moderation, scheduling and customer-service triage are excluded.

Key dates

May 17, 2024✓Original Colorado AI Act (SB 24-205) signed
Aug 28, 2025✓SB 24-205 start date delayed to 30 June 2026 (SB25B-004)
May 14, 2026✓SB 26-189 signed: repeals and replaces SB 24-205
Jan 1, 2027UpcomingSB 26-189 takes effect; AG rules due
Jan 1, 2030Upcoming60-day cure period sunsets

What you have to do

Map every tool that materially influences decisions about jobs, credit, housing, insurance, education, healthcare or public services for Colorado consumers.
Give clear, conspicuous notice before a covered ADMT is used in a consequential decision.
Within 30 days of an adverse decision, explain the tool's role, the data types used and the principal reasons.
Offer a way to correct inaccurate personal data and to request meaningful human review where commercially reasonable.
If you develop an ADMT, supply deployers with technical documentation and warn them of material changes.
Keep records that show how each notice and explanation was produced.

Penalties

Violations are deceptive trade practices under the Colorado Consumer Protection Act, with penalties of up to $20,000 per violation. Attorney General enforcement only, with a 60-day cure opportunity (until 1 January 2030) except for knowing or repeated violations.

Related lessons

Level 1What AI compliance is (and who the rules target)6 min
Level 1The world map of AI rules: EU, US patchwork, Canada, standards8 min
Level 2Build your AI inventory6 min
Level 2Risk classification: prohibited, high-risk, limited, minimal8 min
Level 2Data and privacy basics for AI7 min
Level 2Transparency and disclosure: telling people AI is involved7 min
Level 3Human oversight that actually works6 min
Level 3Bias and fairness testing, including bias audits8 min
Level 3Vendors and contract clauses6 min
Level 3Documenting decisions: records and impact assessments7 min
Level 4Incident response and monitoring7 min
Level 4Training and AI literacy programmes6 min
Level 5Preparing for enforcement, investigations and appeals7 min
Level 5Staying current: key dates ahead and how to track change6 min

Real cases

Settlement2023 · US-federal
EEOC v. iTutorGroup — hiring software that auto-rejected older applicants
Settlement announced 9 August 2023 (EEOC v. iTutorGroup, Inc., No. 1:22-cv-02565, E.D.N.Y.). iTutorGroup agreed to pay $365,000 to rejected applicants, adopt new anti-discrimination policies and training, stop asking for birth dates, invite previously rejected applicants to re-apply if US hiring resumes, and accept EEOC monitoring for five years. The company did not admit wrongdoing.
Lawsuit2025 · US-federal
Mobley v. Workday — collective action over AI hiring screens (ongoing)
Ongoing as of September 2026. In July 2024 the court refused to dismiss the case, accepting the agent theory. On 16 May 2025 it conditionally certified a nationwide ADEA collective of applicants aged 40+ rejected via Workday's platform since September 2020; the opt-in notice period closed on 7 March 2026. In June 2026 the court let California FEHA claims and a proxy-discrimination disability claim proceed. No trial date, judgment or settlement has been reported.
Settlement2024 · US-federal
Louis v. SafeRent — $2.275 million settlement over algorithmic tenant scoring
Settlement approved by the court on 20 November 2024: SafeRent pays $2.275 million (up to $1.175 million to class members) and, for five years, will not produce a SafeRent Score or accept/deny recommendation for applicants using housing vouchers unless a fair-housing expert validates a new model. The court awarded $1.1 million in attorneys' fees.

Industries where it matters

Sources

Last reviewed Sep 25, 2026.