Colorado Delays AI Law Implementation - HR ALERTS

Colorado Delays AI Law Implementation

Now Effective: June 30, 2026

Formerly Effective: February 1, 2026

On September 5, 2025, the rollout of Colorado’s Artificial Intelligence Discrimination Law (S.B. 205) has been delayed. Instead of taking effect February 1, 2026, employers now have until June 30, 2026 to comply. Lawmakers are expected to propose amendments before the new effective date.

What the Law Does

• Applies to businesses that use AI to make or influence consequential decisions (e.g., hiring, promotions, housing, health care).

• Defines a consequential decision as one with a “material legal or similarly significant effect” on employment or access to critical services.

• Covers both developers and users of AI systems.

Employer Compliance Requirements (as written)

• Adopt a risk-management policy for AI systems.

• Complete impact assessments.

• Provide summary statements explaining how AI is used and how risks are managed.

• Issue adverse action notices if AI influenced a decision against an individual.

• Self-report any discoveries of algorithmic discrimination.

What May Change

• Lawmakers have signaled interest in narrowing the scope of the law before June 2026 by:

  • Adjusting the definition of algorithmic discrimination.

  • Limiting which types of decisions are covered.

  • Exempting smaller employers.

Reference: CO S.B. 205

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