Colorado passed the first comprehensive US state AI law, SB 24-205, in 2024. It never took effect. After repeated delays and a special session, the legislature repealed and replaced it in May 2026 with SB 26-189, a narrower automated-decision law. The original duty of care against algorithmic discrimination, risk-management programs, and impact assessments are gone. The replacement focuses on disclosures and consumer rights around automated decision-making technology and takes effect January 1, 2027, the same day as a separate chatbot safety law, HB 26-1263. The attorney general is writing rules for both, released a regulatory analysis on October 21, and set the rulemaking hearing for October 26, 2026. A federal court order in xAI's lawsuit bars enforcement of the ADMT law for conduct through 14 days after a ruling on xAI's preliminary-injunction motion, which xAI must file within 28 days after the rules are adopted. Colorado was the only state named in the December 2025 federal preemption order.
Key points
- SB 24-205, the original Colorado AI Act, was delayed from February 2026 to June 30, 2026, then repealed before it ever applied.
- SB 26-189, signed May 14, 2026, replaces it with an ADMT transparency regime effective January 1, 2027.
- The replacement drops the duty of care, risk programs, and impact assessments.
- It adds pre-use consumer notices, explanations of adverse decisions within about 30 days, and human-review rights.
- Penalties up to $20,000 per violation; Attorney General enforcement only; no private right of action.
- Enforcement is on hold. xAI sued in federal court on April 9, 2026, and the Justice Department intervened on April 24 on equal-protection grounds, the AI Litigation Task Force's first action against a state AI law. An April 27 order in X.AI LLC v. Weiser, entered on the parties' joint motion, bars the attorney general from opening enforcement or investigations under SB 24-205 or any 2026 law replacing or amending it, which covers SB 26-189, for conduct through 14 days after the court rules on xAI's preliminary-injunction motion. xAI must file that motion within 28 days after the rules are finally adopted.
- HB 26-1263, signed May 29, 2026, regulates conversational AI services from January 1, 2027: disclosure that the user is talking to a machine, protocols for suicidal ideation, no engagement rewards for minors, and no implying that output comes from a licensed professional.
- The attorney general filed proposed ADMT and chatbot safety rules on August 11, 2026, took a first round of comments to September 4, posted a revised interim draft on October 6, released a regulatory analysis on October 21 finding that the rules' benefits outweigh their costs, and set the rulemaking hearing for October 26, 2026, with final comments due that day, or on the last day of the hearing if it continues, so the rules are in place for January 1, 2027.
Laws and instruments
Colorado Artificial Intelligence Act (original)
SB 24-205 (2024)
The first comprehensive US state AI law. Imposed a duty of reasonable care to prevent algorithmic discrimination in consequential decisions. Repealed and replaced in 2026.
Effective: Repealed before taking effect
Colorado ADMT Act (replacement)
SB 26-189 (signed May 14, 2026)
Regulates automated decision-making technology that materially influences consequential decisions. Requires pre-use notices, adverse-decision explanations, human review, and developer documentation. The attorney general has exclusive enforcement and is in formal rulemaking: proposed rules filed August 11, 2026, a first comment round to September 4, a revised interim draft posted October 6 (adding, among other things, a rebuttable presumption that a score, ranking, or classification of a person materially influences a decision when the decision-maker reviews it and the outcome matches it, adverse-outcome disclosures within 30 days, and 45-day access and correction responses), a regulatory analysis on October 21, and a hearing on October 26, 2026 in Denver, with final comments due that day or on the hearing's last day if it continues.
Effective: January 1, 2027; attorney general rules due by that date, with the rulemaking hearing and final comments on October 26, 2026
HB 26-1263: Conversational AI service operator requirements
HB 26-1263 (2026), signed May 29, 2026
Requires operators of conversational AI services to disclose that users are interacting with artificial intelligence, to follow protocols when a user shows signs of suicidal ideation or self-harm, and to avoid implying that output comes from a licensed professional. For minors it bars engagement rewards such as points, badges, and streaks and requires technically feasible measures against sexually explicit material and simulated emotional dependence. Violations are deceptive trade practices under the Colorado Consumer Protection Act, and the attorney general's chatbot safety rules are being written alongside the ADMT rules.
Effective: January 1, 2027
Timeline
- May 2024
SB 24-205 enacted.
- August 28, 2025
Effective date delayed to June 30, 2026.
- April 9, 2026
xAI sues in federal court to block SB 24-205.
- April 24, 2026
The Justice Department intervenes on equal-protection grounds, the AI Litigation Task Force's first action against a state AI law.
- April 27, 2026
Court order on a joint motion: no enforcement of SB 24-205, or of any 2026 law replacing it, for conduct through 14 days after a ruling on xAI's preliminary-injunction motion.
- May 14, 2026
SB 26-189 repeals and replaces the original act.
- May 29, 2026
HB 26-1263, the conversational AI safety law, is signed; it takes effect January 1, 2027.
- August 11, 2026
The attorney general files proposed ADMT and chatbot safety rules with the Secretary of State.
- October 6, 2026
The attorney general posts a revised interim draft of the ADMT and chatbot safety rules.
- October 21, 2026
The attorney general releases a regulatory analysis of the ADMT and chatbot safety rules, requested by a member of the public, concluding that their benefits outweigh their costs.
- October 26, 2026
Rulemaking hearing in Denver on the attorney general's ADMT and chatbot safety rules; final comments due that day, or on the hearing's last day if it continues.
- January 1, 2027
Replacement ADMT law takes effect.
Who it applies to
Under the replacement, deployers and developers of ADMT that influences consequential decisions about Colorado residents, including employees and job applicants. From January 1, 2027 the chatbot safety law reaches operators of conversational AI services available to Colorado users.
Penalties
Up to $20,000 per violation of the ADMT law; Attorney General enforcement; no private right of action. Violations of the chatbot safety law are deceptive trade practices under the Colorado Consumer Protection Act. Under the April 27 court order, the attorney general cannot open enforcement or investigations under the ADMT law for conduct through 14 days after the court rules on xAI's preliminary-injunction motion.
Recent developments
Colorado repeals its landmark AI Act and replaces it with a narrower ADMT law
Governor Polis signed a bill repealing the first comprehensive US state AI law before it ever took effect. The replacement drops the duty of care, risk programs, and impact assessments, and instead regulates automated decision-making technology through disclosures and consumer rights, effective January 1, 2027.
April 24, 2026
Jenner & Block
The Justice Department joins xAI's challenge to the Colorado AI Act
xAI sued on April 9 to block SB 24-205, arguing that it compels speech, burdens interstate commerce, and is unconstitutionally vague. The Justice Department intervened on April 24 on equal-protection grounds alone, arguing that disparate-impact liability pushes developers to discriminate. A stipulated order three days later put enforcement on hold pending a preliminary-injunction ruling, and in May the legislature repealed and replaced the act.
Common questions
Does Colorado have a comprehensive AI law?
Not anymore. Colorado passed the first comprehensive US state AI law, SB 24-205, in 2024. It never took effect. After repeated delays and a special session, the legislature repealed and replaced it in May 2026 with SB 26-189, a narrower automated-decision law. The original duty of care against algorithmic discrimination, risk-management programs, and impact assessments are gone. The replacement focuses on disclosures and consumer rights around automated decision-making technology and takes effect January 1, 2027, the same day as a separate chatbot safety law, HB 26-1263. The attorney general is writing rules for both, released a regulatory analysis on October 21, and set the rulemaking hearing for October 26, 2026. A federal court order in xAI's lawsuit bars enforcement of the ADMT law for conduct through 14 days after a ruling on xAI's preliminary-injunction motion, which xAI must file within 28 days after the rules are adopted. Colorado was the only state named in the December 2025 federal preemption order.
What are the penalties for AI violations in Colorado?
Up to $20,000 per violation of the ADMT law; Attorney General enforcement; no private right of action. Violations of the chatbot safety law are deceptive trade practices under the Colorado Consumer Protection Act. Under the April 27 court order, the attorney general cannot open enforcement or investigations under the ADMT law for conduct through 14 days after the court rules on xAI's preliminary-injunction motion.
Who does AI regulation in Colorado apply to?
Under the replacement, deployers and developers of ADMT that influences consequential decisions about Colorado residents, including employees and job applicants. From January 1, 2027 the chatbot safety law reaches operators of conversational AI services available to Colorado users.
Cite this page
Artificial Intelligence Regulations, "AI Regulation in Colorado," reviewed October 26, 2026, https://artificialintelligenceregulations.com/jurisdictions/colorado.html.
Entries state the position as of the review date and link to the primary text for verification.
