Colorado rewrites its AI Act: lighter obligations, new January 1, 2027 date

What changed Colorado lawmakers rewrote the state's artificial intelligence law. S.B. 26-189 scales back the prior risk-management framework, shifting from a risk-based model to a transparency-based one, and pushes the effective date to January 1, 2027. Employers acting as "deployers" of automated decision-making systems still face meaningful notice and disclosure obligations at multiple stages of the employment relationship. Who it applies to Employers using automated decision-making in consequential employment decisions affecting Colorado residents. What HR needs to do - Use the extra runway. Build the AI tool inventory and vendor documentation file now; it is the same work Illinois and Connecticut require. - Map where notices must appear: before use, at the decision, and on adverse action. - Standardize a single multi-state AI notice rather than one per jurisdiction. - Assign an owner. AI governance drifts between HR, legal and IT until someone is accountable. Related Connecticut also enacted employer AI governance obligations this year, with notice duties, anti-discrimination requirements and civil penalties.