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United States — ColoradoIn forceRelevance to Chinese AI firms: HighAI regulationData & privacy

Colorado Artificial Intelligence Act

Concerning consumer protections in interactions with artificial intelligence systems (SB24-205)

Colorado General Assembly · C.R.S. 6-1-1701 至 6-1-1707(SB24-205,经 SB25B-004 修订)

The act centres on algorithmic discrimination and imposes a duty of reasonable care on developers and deployers of high-risk AI systems, offering a rebuttable presumption in exchange for compliance: a developer that supplies the required documentation, publishes the required statement and gives the 90-day algorithmic discrimination notice is presumed to have used reasonable care, and so is a deployer that implements the risk management policy and program, completes impact assessments and provides consumer notice with correction and appeal rights. Compliance with a recognized framework such as the NIST AI Risk Management Framework or ISO/IEC 42001, combined with discovering and curing violations through feedback, adversarial testing or internal review, is an affirmative defence. Enforcement rests exclusively with the Attorney General, a violation constitutes an unfair trade practice under the Colorado Consumer Protection Act, and there is no private right of action.

Verified against official sources · 2026-09-12Verified against official text

Does this apply to me?

A Chinese AI company is caught when it: (1) sells or licenses to Colorado business customers an AI system used for consequential decisions such as employment screening, performance evaluation, credit underwriting, insurance pricing, housing, education admissions, healthcare or legal services, which makes it a developer owing the statutory documentation package; (2) substantially modifies a third-party foundation model before making it available, which also makes it a developer; (3) uses such a system itself in Colorado to screen job applicants or customers, which makes it a deployer owing risk management and impact assessments; or (4) offers Colorado consumers any AI system intended to interact with them, high-risk or not, which triggers the interaction disclosure. Supplying indirectly through a U.S. reseller or SaaS platform does not change developer status.

Key industries: All industries, Enterprise SaaS, GenAI & foundation models, Healthcare AI, Fintech AI, Computer vision

Application timeline

  1. 2024-05-17

    Governor signs SB24-205

    The act becomes law, with the substantive duties keyed to a separate start date.

  2. 2025-08-28

    Governor signs the delay bill SB25B-004

    Passed in the 2025 Extraordinary Session, extending the SB24-205 requirements to 2026-06-30; the delay bill itself took effect 2025-11-25.

  3. 2026-06-30

    Developer and deployer duties begin to apply

    The duty of reasonable care, developer documentation and public statement, deployer risk management policy and impact assessments, consumer notice and appeal, AI interaction disclosure and the 90-day Attorney General notice all apply.

Obligations (7)

Each states its trigger, the evidence to retain and the clause it comes from

Developer disclosures and documentation to deployers

Severity HighC.R.S. 6-1-1702(2)-(3)

A developer of a high-risk AI system must make available to deployers and other developers a general statement of reasonably foreseeable uses and known harmful or inappropriate uses; documentation disclosing high-level summaries of the training data types, known or reasonably foreseeable limitations including algorithmic discrimination risks, the purpose, intended benefits and uses, and all other information the deployer needs to comply with section 6-1-1703; and documentation describing how the system was evaluated for performance and discrimination mitigation before release, the data governance measures applied to training datasets and the review of data source suitability and bias, intended outputs, mitigation measures taken, and how the system should and should not be used and monitored by a human when making a consequential decision.

Applies when
Chinese AI companies supplying systems used for consequential decisions in Colorado such as employment screening, credit scoring, education admissions, healthcare, housing, insurance or legal services, including where supply is indirect through a U.S. reseller or SaaS channel.
Applies from: 2026-06-30
Evidence to retain
  • · High-risk system statement covering intended uses, limitations and prohibited uses
  • · Model card and dataset card including high-level training-data summaries and data governance measures
  • · Pre-release performance and algorithmic discrimination evaluation report
  • · Delivery log and version register for documentation provided to deployers

Estimated first-time effort: 10–25 person-days (estimate, not a commitment)

Developer public statement and 90-day algorithmic discrimination notice to the Attorney General

Severity HighC.R.S. 6-1-1702(4)-(5)

A developer must publish a statement summarizing the types of high-risk systems it has developed or intentionally and substantially modified and currently makes available, and how it manages known or reasonably foreseeable risks of algorithmic discrimination. It must also disclose to the Colorado Attorney General and to known deployers and other developers, within 90 days after discovery or receipt of a credible report from a deployer, that the high-risk system has caused or is reasonably likely to have caused algorithmic discrimination.

Applies when
Any entity meeting the developer definition, including Chinese companies that substantially modify a third-party foundation model before making it available.
Deadline: Within 90 days after discovery or receipt of a credible report
Applies from: 2026-06-30
Evidence to retain
  • · Archived copy of the public statement with update timestamps
  • · Algorithmic discrimination incident register recording discovery date, source and assessment
  • · Copies of the 90-day notices sent to the Attorney General and to deployers
  • · Investigation and remediation records for each incident

Estimated first-time effort: 3–10 person-days (estimate, not a commitment)

Deployer risk management policy and program

Severity HighC.R.S. 6-1-1703(2), (6)

A deployer must implement a risk management policy and program specifying the principles, processes and personnel used to identify, document and mitigate known or reasonably foreseeable risks of algorithmic discrimination, iterated and systematically reviewed and updated over the system life cycle. Reasonableness is assessed against the latest NIST AI Risk Management Framework, ISO/IEC 42001 or another nationally or internationally recognized framework that is substantially equivalent to or more stringent than part 17 (or a framework designated by the Attorney General), together with the size and complexity of the deployer, the nature and scope and intended uses of the systems deployed, and the sensitivity and volume of the data processed.

Applies when
Entities using high-risk AI systems to make consequential decisions in Colorado, including the hiring, credit or customer-screening teams of Chinese companies in the United States. An exemption applies only where all conditions are met, including employing fewer than 50 full-time equivalent employees and not using the deployer own data to train the system.
Applies from: 2026-06-30
Evidence to retain
  • · Risk management policy and program text identifying the reference framework and version
  • · Roster of personnel responsible for identifying, documenting and mitigating risks
  • · Periodic review and update records showing dates and changes
  • · Exemption assessment covering full-time equivalent headcount and use of deployer data for training

Estimated first-time effort: 15–40 person-days (estimate, not a commitment)

Deployer impact assessments, annually and after substantial modification

Severity HighC.R.S. 6-1-1703(3)

A deployer, or a third party it contracts with, must complete an impact assessment for each high-risk system it deploys, at least annually and within 90 days after an intentional and substantial modification is made available. The assessment must at minimum state the purpose, intended use cases, deployment context and benefits, and analyse whether deployment poses known or reasonably foreseeable risks of algorithmic discrimination, the nature of any such discrimination and the mitigation steps taken, along with the other statutory elements. Records must be retained for at least three years following the final deployment.

Applies when
As above; required whenever the small-deployer exemption conditions are not fully satisfied.
Deadline: Before deployment, at least annually, and within 90 days of a substantial modification; retain for at least three years
Applies from: 2026-06-30
Evidence to retain
  • · Impact assessment reports covering the initial, annual and post-modification versions
  • · Developer documentation and internal test data relied on in the assessment
  • · Archive index evidencing three-year retention of impact assessment records
  • · Records of reassessment within 90 days of a substantial modification

Estimated first-time effort: 8–20 person-days (estimate, not a commitment)

Consumer notice, reasons, correction and human-review appeal

Severity HighC.R.S. 6-1-1703(4)

Where a high-risk system makes, or is a substantial factor in making, a consequential decision, the deployer must notify the consumer directly and in plain language. If the decision is adverse, the deployer must also provide a statement of the principal reasons, including the degree and manner in which the system contributed, the type of data processed and its sources; an opportunity to correct incorrect personal data that was processed; and an opportunity to appeal, allowing human review where technically feasible unless appeal is not in the best interest of the consumer, such as where delay would risk life or safety.

Applies when
Deployers using AI to support consequential decisions in Colorado in areas such as employment, credit, insurance, housing, education and healthcare.
Applies from: 2026-06-30
Evidence to retain
  • · Consumer notice template and dispatch records
  • · Adverse-decision reasons template including data type and source fields
  • · Log of data correction requests and their handling
  • · Records of appeals received, human review performed and outcomes

Estimated first-time effort: 10–25 person-days (estimate, not a commitment)

Deployer 90-day algorithmic discrimination notice to the Attorney General

Severity HighC.R.S. 6-1-1703(7), (9)

A deployer that discovers, after deployment, that a high-risk system has caused algorithmic discrimination must send a disclosure notice to the Attorney General without unreasonable delay and no later than 90 days after discovery, in the form and manner the Attorney General prescribes. The Attorney General may also require the deployer, or a third party it contracts with, to produce the risk management policy, impact assessment or records within 90 days of a request.

Applies when
All entities deploying high-risk AI systems in Colorado.
Deadline: Within 90 days of discovery; production at the Attorney General request within 90 days
Applies from: 2026-06-30
Evidence to retain
  • · Discovery and internal escalation records, including the basis for the discovery date
  • · Disclosure notice filed with the Attorney General and the filing receipt
  • · Index and submission record of materials produced at the Attorney General request
  • · Remediation plan and verification results

Estimated first-time effort: 2–8 person-days (estimate, not a commitment)

Disclose to consumers that they are interacting with an AI system

Severity MediumC.R.S. 6-1-1704

A person doing business in Colorado that deploys or makes available an AI system intended to interact with consumers must ensure that each consumer interacting with the system is disclosed that they are interacting with an AI system. This duty is not limited to high-risk systems and applies to consumer-facing conversational products.

Applies when
Chinese companies offering AI customer service, AI assistants or companion conversational products to consumers in Colorado.
Applies from: 2026-06-30
Evidence to retain
  • · Interface disclosure copy and screenshots for every entry point
  • · Product requirement documents and release records for the disclosure logic
  • · Consistency checks across localized versions
  • · Memo on any reliance on the obviousness exception

Estimated first-time effort: 2–6 person-days (estimate, not a commitment)

Penalties

The Attorney General has exclusive enforcement authority and rulemaking power, and a violation is an unfair trade practice under Colorado Consumer Protection Act section 6-1-105(1)(hhhh). The part provides no private right of action, and the rebuttable presumption and affirmative defence apply only in Attorney General actions. Monetary penalties follow the Colorado Consumer Protection Act and were not verified item by item in this pass.

Known uncertainty

The signed SB24-205 text uses the phrase on and after February 1, 2026 throughout. That date was extended to 2026-06-30 by SB25B-004, passed in the 2025 Extraordinary Session, whose Colorado General Assembly page states that the act extends the effective date of the SB24-205 requirements to June 30, 2026. This entry uses the extended date in the timeline and in each obligation effectiveFrom, although the statutory text still reads February 1. In addition, the Attorney General has rulemaking authority under 6-1-1707, so notice formats, reporting methods and record requirements may be further specified by rule.

Related standards

  • NIST Artificial Intelligence Risk Management Framework 1.0 (NIST AI 100-1) · AI RMF 1.0 (NIST AI 100-1, released 2023-01-26; being revised under the White House AI Action Plan)
  • ISO/IEC 42001 Artificial Intelligence Management System (AIMS) · ISO/IEC 42001:2023 (edition 1, dated 2023-12); European adoption EN ISO/IEC 42001:2026
  • ISO/IEC 42005:2025 Artificial intelligence — AI system impact assessment · ISO/IEC 42005:2025 (adopted identically in Australia as AS ISO/IEC 42005:2025)

Sources (3)

Content as of 2026-09-12 · corpus 2026.09|Compiled from public official sources with links and review dates for compliance decision support. Rules change; have licensed professionals review before external disclosure, regulatory filing or contractual commitments.

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Colorado Artificial Intelligence Act · Obligations & official sources | HaiWen HQ