June 2026 is not the live Colorado calendar. SB24-205's high-risk AI program was repealed and reenacted. SB26-189, listed as enacted on the General Assembly bill page, moves the job to ADMT notice rules with duties starting 1 January 2027.

The news

The Colorado General Assembly page for SB26-189, session 2026 Regular Session, titles the bill "Concerning the use of automated decision-making technology in consequential decisions, and, in connection therewith, making an appropriation." The enacted bill summary states that in 2024 the General Assembly enacted Senate Bill 24-205, and that this act repeals and reenacts those provisions.

The summary defines automated decision-making technology as technology that processes personal data and uses computation to generate output, including predictions, recommendations, classifications, rankings, scores, or other information, used to make, guide, or assist a decision concerning an individual. A consequential decision relates to access to, eligibility for, or compensation related to education, employment, housing, financial or lending services, insurance, health-care services, or essential government services and public benefits.

Starting 1 January 2027, a developer of a covered ADMT must give a deployer technical documentation on intended uses, categories of training data, known limitations, and instructions for appropriate use and human review, and must notify deployers of material updates. Developers and deployers must retain records necessary to demonstrate compliance for at least three years.

Deployers must give clear notice at the point of interaction with a covered ADMT and, within 30 days after a covered ADMT produces a consequential decision with an adverse outcome, a plain-language description of the ADMT's role. Consumers may request personal data used, correction of factually incorrect personal data, and meaningful human review and reconsideration after an adverse outcome. The attorney general must adopt rules clarifying the post-adverse-outcome disclosures by 1 January 2027, and enforces through the Colorado Consumer Protection Act.

Who is bound

The Colorado General Assembly shipped the statute. The attorney general is directed to write rules and enforce. Developers of covered ADMT and deployers who use it to materially influence consequential decisions in the listed domains are bound if they are subject to Colorado's consumer-protection reach.

Employers, lenders, insurers, health systems, landlords, schools, and public-benefit agencies that use scoring or ranking tools on Colorado consumers are the practical deployer class. Specified entities are exempted to the extent they comply with other legal obligations, the enacted summary states. The full exemption list is in the enrolled text, not in the one-page summary.

Skadden's 9 June 2026 client alert states Governor Jared Polis signed the Automated Decision-Making Technology Act on 14 May 2026, that xAI sued in April 2026 to enjoin the prior CAIA, and that the federal government moved to intervene. Those litigation facts are Skadden's account. The Frontier did not retrieve a complaint PDF or a governor's signature page.

What's new

The live Colorado framework, as summarized on the official bill page, is ADMT transparency and consumer recourse: developer packs, point-of-use notice, 30-day adverse-outcome explanation, data access/correction, human review. It is not the 2024 high-risk AI risk-management and algorithmic-discrimination program described in contemporaneous law-firm alerts. Treat those alerts as secondary. The statute the bill page says was repealed-and-replaced is SB24-205.

The operative date in the enacted summary and in the Senate committee report language quoted in legislative PDFs is 1 January 2027, with attorney-general rulemaking as a gating item for disclosure detail.

What it does not settle

Region: Colorado Consumer Protection Act enforcement. Extra-territorial reach for non-Colorado developers is UNKNOWN pending rules and cases. Dates: committee votes 5–8 May 2026; Skadden states signature 14 May 2026; developer/deployer duties "starting January 1, 2027"; AG disclosure rules due by that date. Price: no statutory fee schedule in the summary. Hardware: none. Data: personal data used by covered ADMT, with a three-year record-retention floor. License: not a software-license event. Whether the 1 January 2027 duties are delayed if AG rules are late is UNKNOWN from the summary page.

What to do now

Product counsel for hiring, credit, insurance, housing, and benefits tools used on Colorado residents should map which systems meet the ADMT and consequential-decision definitions, and should not keep a 30 June 2026 SB24-205 workplan as the compliance date. Developers should start the documentation pack the summary requires (intended uses, training-data categories, known limitations, human-review instructions) even though the duty date is 2027.

Whether Governor Polis's signature page is posted on colorado.gov is UNKNOWN.