In our recent post, AI Regulation on Hold in Colorado—But Employer Risk Isn’t, we flagged that delay did not mean diminished risk. That continues to hold true. Colorado has now approved a comprehensive rewrite of its AI law, while Illinois regulators are advancing practical disclosure requirements for employers using AI in employment decisions.

The direction is clear: AI oversight in the workplace is moving forward—and becoming more operational.

Colorado: Recalibration, Not Retreat

Colorado’s rewrite reflects an effort to make its AI framework more workable—but not less relevant for employers.

Key points:

• Employment uses remain in scope: AI tools used in hiring, promotion, and other employment decisions continue to be treated as “high risk.”
• Governance expectations remain: Employers will still need risk management and oversight frameworks.
• Transparency still matters: Notice and documentation obligations continue, even as details evolve.

Takeaway: Colorado is refining its approach, not stepping back. Employers should expect continued compliance obligations—just with clearer contours. For further details on the rewrite, please see our colleagues’ post, Colorado Legislature Approves Comprehensive Rewrite of State AI Law.

Illinois: A Practical Preview of Compliance

At the same time, Illinois is showing what compliance may look like on the ground.

Proposed regulations from the Illinois Department of Human Rights would require employers to:

• Notify applicants and employees...

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