Quick Hit: In 2024, Colorado enacted the Colorado Artificial Intelligence Act (the “AI Act”), the most comprehensive measure regulating the use of AI in the nation. As the law’s June 30, 2026 effective date approaches, and given the significant concerns raised about the AI Act, on March 17, 2026, the Colorado AI Policy Work Group (the “Work Group”), with Governor Jared Polis’s backing, released a proposed framework (the “Proposal”) that would replace much of the original AI Act with a more streamlined regime. If enacted, the Proposal would also delay the law’s effective date from June 30, 2026 to January 1, 2027.
Key Takeaways: Colorado’s AI Act has been a source of concern for employers since it was enacted in 2024. It is the most comprehensive AI law in the country and, if it goes into effect without changes, will impose a host of onerous requirements on employers, including implementation of risk management programs, impact assessments, annual reviews, and disclosures regarding algorithmic discrimination. The Proposal would eliminate many of these requirements and impose a far narrower framework that would focus on transparency and notice. Of course, it remains to be seen whether and to what extent the Proposal will be adopted. While this development is a positive one for employers, the AI Act remains set to go into effect on June 30, 2026. Employers should monitor developments but be aware that the amendments may not be enacted, and should therefore be preparing to...
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