The short answer
The effective date needs care. SB24-205 never took effect. It was delayed, challenged in court, and then repealed and replaced by SB26-189, signed on 14 May 2026. The new law applies to consequential decisions made on or after 1 January 2027.
Timeline
| Date | Event |
|---|---|
| 17 May 2024 | SB24-205 signed; original effective date 1 February 2026 |
| 28 Aug 2025 | SB25B-004 signed, moving the effective date to 30 June 2026 |
| 9 Apr 2026 | xAI sues over the law |
| 27 Apr 2026 | Court bars enforcement pending a preliminary injunction ruling |
| 14 May 2026 | SB26-189 signed, repealing and replacing SB24-205 |
| Aug-Oct 2026 | Attorney General rulemaking on ADMT and chatbot safety rules |
| 1 Jan 2027 | SB26-189 applies |
What SB24-205 would have required
Developers and deployers of high-risk AI had a duty of reasonable care to avoid algorithmic discrimination, with risk-management programs, impact assessments, consumer notices, and reporting to the Attorney General. Following a recognized framework such as the NIST AI RMF gave an affirmative defense.
What SB26-189 requires
The new law moves from a duty-of-care model to transparency and consumer rights for automated decision-making technology (ADMT). Deployers must:
- Give notice that ADMT is used.
- Send a plain-language explanation within 30 days of an adverse decision.
- Allow correction of inaccurate data.
- Offer meaningful human review.
A violation is a deceptive trade practice. The Attorney General must adopt rules before 1 January 2027; proposed rules were filed on 11 August 2026 and a hearing was set for 26 October 2026. A companion Chatbot Safety Act (HB26-1263) also takes effect on 1 January 2027.
Reuse terms
The Colorado legislature’s website warns that information “may be incorrect or obsolete” and should not be relied on as an official record; it has no copyright statement. For the Colorado Revised Statutes, the state stopped claiming copyright in 2016, but republishers must notify the Committee on Legal Services and may not present copies as official. State works are not covered by the federal rule in 17 U.S.C. 105. Paraphrase summaries and link to sources.
Using Colorado law in AI and RAG
- Mark SB24-205 as repealed and keep it only for history.
- Index SB26-189 with its 1 January 2027 date, and add AG rules when final.
- Use the Governor’s release or the official summary for status; the bill page may lag.
- Map ADMT decisions in your products to notice, explanation, correction, and human review duties.
- Watch litigation, which may affect enforcement.
Common mistakes
- Preparing for SB24-205 impact assessments that no longer apply.
- Citing the 30 June 2026 date.
- Relying on an out-of-date bill status page.
- Ignoring the AG’s rules.
Checklist
- SB24-205 marked repealed
- SB26-189 duties mapped to products
- AG rules tracked
- Adverse decision explanation process ready
- Human review process ready
How AskDona helps
AskDona compares your ADMT notices, explanation templates, and review procedures with SB26-189 and the AG rules you load, showing gaps with citations.
Run a sample Colorado ADMT readiness check
AskDona shows the evidence; your legal team decides.
Editor’s note. This article is general information, not legal advice. Some SB26-189 details come from law firm analyses and the state summary. The “check required” rating is our first-pass judgment.
FAQ
Is the Colorado AI Act in effect? The original SB24-205 never took effect. It was replaced by SB26-189, which applies from 1 January 2027.
What does the new law require? Notice of ADMT use, explanations of adverse decisions, data correction, and human review.
Who enforces it? The Attorney General, as a deceptive trade practice.
Does the NIST AI RMF still matter? It was an affirmative defense under SB24-205; it remains useful practice but SB24-205 is repealed.
References
All pages opened and checked by October 26, 2026.
| Source | What it supports |
|---|---|
| Colorado General Assembly: SB24-205 | Original bill |
| LegiScan: SB24-205 | Signed 17 May 2024 |
| Colorado General Assembly: SB25B-004 | Delay to 30 June 2026 |
| Governor Polis: Bills signed | SB26-189 signed 14 May 2026 |
| Colorado DRE: SB26-189 summary | Duties, 1 Jan 2027, enforcement |
| Colorado AG: AI rulemaking | Rulemaking timeline |
| Proskauer: Colorado AI law developments | Litigation and stay |
| Colorado Revised Statutes data | Republication rules |