News & Analysis as of

Colorado

Paul Hastings LLP

Colorado Enacts New Narrower, Less Burdensome AI Law

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On May 14, Colorado Gov. Jared Polis signed Senate Bill 26-189 (the Act), an overhaul of Colorado’s 2024 law governing the use of automated decision-making technology (ADMT), Senate Bill 24-205. Key provisions of the prior...more

Blank Rome LLP

Colorado Replaces AI Act with Narrower New AI Law

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Colorado Governor Jared Polis signed Senate Bill 189 (“SB 189”), a bill that repeals and replaces the 2024 Colorado AI Act with a narrower, more business-friendly framework focused on automated decision-making technology...more

Wilson Sonsini Goodrich & Rosati

Colorado Legislature Repeals and Replaces Colorado AI Act: What SB 189 Means for Your Business

On May 14, 2026, Colorado Governor Jared Polis signed SB 189 into law, which repeals and replaces the Colorado Artificial Intelligence Act (CAIA). SB 189 goes into effect on January 1, 2027....more

Nelson Mullins Riley & Scarborough LLP

Colorado Legislature Doubles Back on Risk-Based AI Act

This is part of a series from Nelson Mullins' AI Task Force. We will continue to provide additional insight on both domestic and international matters across various industries spanning both the public and private sectors....more

Sheppard

Rocky Mountain Rewrite: Colorado’s AI Law Gets an Overhaul

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Colorado became the first state in the country to pass a sweeping law regulating how businesses use artificial intelligence in 2024. Governor Polis expressed concerns about the law at that time and called for revisions before...more

Buchalter

Colorado Rewrites Its AI Law: What Employers Must Know About SB 26-189

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On May 14, 2026, Governor Polis signed Senate Bill 26-189 into law, repealing and replacing Colorado’s 2024 landmark AI law. Senate Bill 26-189 — A Bill Concerning the Use of Automated Decision-Making Technology in...more

Seyfarth Shaw LLP

Colorado’s AI Reset: Two Weeks, a White House Callout, and a Pivot Away from the EU Model

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When Colorado enacted the first comprehensive state AI law in 2024, it imported the conceptual architecture of the EU AI Act: a risk-based regime built on duties of care, risk management programs, and impact assessments. Two...more

Jackson Lewis P.C.

Colorado’s New AI Law Shifts Employer Accountability from System to Individual Decision Level

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On May 1, 2026, Colorado lawmakers introduced a bill that would repeal and replace the state’s 2024 artificial intelligence (AI) statute weeks before its June 30, 2026, effective date. Governor Jared Polis signed it into law...more

Baker Botts L.L.P.

AI Legal Watch: May 2026

Baker Botts L.L.P. on

On April 9, 2026, X.AI LLC ("xAI") filed a complaint for declaratory and injunctive relief in the U.S. District Court for the District of Colorado (X.AI LLC v. Weiser, No. 1:26-cv-01515) against Colorado Attorney General...more

Troutman Pepper Locke

Proposed State Privacy and AI Law Update: May 18, 2026

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Colorado repeals and replaces the Colorado AI Act, Georgia enacts a chatbot law, and California and New York advance numerous bills. Below is the eighteenth update on the status of proposed state privacy and AI...more

Alston & Bird

Colorado Replaces Landmark AI Act—Creating New Trails for AI Rules and Private AI Litigation

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On May 12, 2026, the Colorado legislature passed SB 26-189, which repeals and replaces its landmark Artificial Intelligence Act. Colorado is doing away with the concept of “algorithmic discrimination” and moving instead to a...more

Littler

Colorado Amends its Artificial Intelligence Law, Substantially Reducing Obligations on Employers

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Colorado’s governor has signed an amendment (S.B. 26-189) to Colorado’s artificial intelligence law, substantially reducing the compliance burden on employers. The Colorado General Assembly passed the bill one day before the...more

Baker Botts L.L.P.

Colorado Repeals and Replaces AI Act

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On May 9, 2026, the Colorado General Assembly passed Senate Bill 26-189 (the "Bill"), which repeals and reenacts the previously passes SB 24-25 (Colorado's “AI Act") with comprehensive new requirements governing the use of...more

Troutman Pepper Locke

Colorado Rewrites Its AI Law

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On May 12, the Colorado legislature passed Senate Bill 26‑189, a substantial rewrite of its 2024 law establishing consumer protections for artificial intelligence (formerly referred to as the CO AI Act), and replaced it with...more

Cozen O'Connor

Claims Notes: May 2026

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UIM Exhaustion Does Not Require Payment of Underlying Limits - The Colorado Supreme Court addressed when an excess UIM carrier’s obligations are triggered under an exhaustion provision. The insured argued that excess...more

Baker Botts L.L.P.

Colorado Pioneers First-in-Nation Ban on "Surveillance Pricing" and Algorithmic Wage Setting

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As businesses increasingly rely on AI and algorithmic models to optimize pricing and labor costs, state legislatures are drawing strict boundaries around the data fueling these systems....more

Proskauer - Law and the Workplace

Major Developments Put Colorado’s AI Law on Ice Ahead of Implementation

As the June 30, 2026 effective date of Colorado’s burdensome AI law rapidly approaches, there are new developments that complicate its implementation and raise questions about whether it will ever be implemented in its...more

Ballard Spahr LLP

Colorado Rewrites Its Landmark AI Law: Unpacking SB 26-189 and What It Means for Businesses

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After attempting to amend its first-in-the-nation AI law for two years and three legislative sessions, on May 9, 2026, the Colorado legislature passed SB 26-189. It now awaits the governor’s signature and is expected to be...more

Troutman Pepper Locke

Colorado Legislature Passes Bill to Repeal and Replace Colorado AI Act

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The Colorado legislature passed a bill to replace Colorado’s existing artificial intelligence (AI) law with a more business-friendly regulatory regime focused on disclosures and limited consumer rights but, in doing so, added...more

Brownstein Hyatt Farber Schreck

Colorado Redevelopment Projects Face Impact Fee Exposure: Lessons from Carroll Partners

A recent Colorado appeals court decision clarifies and potentially expands upon when local governments can charge impact fees on development projects. In Carroll Partners LLC v. Board of Commissioners, the court ruled that...more

Fisher Phillips

Colorado Moves to Replace AI Bias Audit Law With New Transparency Framework: Your Guide to Understanding the Changes

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Colorado lawmakers are moving to repeal the state’s first-in-the-nation AI antidiscrimination law and replace the mandatory bias audit and risk impact assessment requirements with a streamlined transparency-and-notice...more

Kelley Drye & Warren LLP

AI Regulatory Roundup: Recent Developments in Colorado, Connecticut, and California

State legislatures continue to move aggressively on artificial intelligence regulation in 2026, with Colorado, Connecticut, and California each advancing significant and distinct AI governance frameworks....more

Houston Harbaugh, P.C.

The Accountability Baseline: Why the "Human-in-the-Loop" is Your Newest Discovery Risk in Insurance Claims Handling

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This is the first installment of a new insurance claims-focused series within Defending the Algorithm™, written and edited by Pittsburgh, Pennsylvania Insurance and Commercial Litigation Attorney Christopher M. Jacobs, Esq.,...more

Davis Wright Tremaine LLP

Trust Issues: May 2026

Using personal information to set consumer pricing has long been a practice in a wide range of industries to some degree, such as through loyalty programs. But some regulators are now criticizing the practice as harmful to...more

Fisher Phillips

Colorado’s Impending AI Law Thrown Into More Doubt By Court Ruling: What Will Happen Before June 30 Effective Date?

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A federal court just ordered Colorado not to enforce the impending AI law set to take effect on June 30 that otherwise would have upended the way employers use AI in the workplace. The April 27 ruling is just the latest...more

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