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 current form.
First, on April 27, 2026, a federal magistrate judge stayed enforcement of Colorado’s Anti-Discrimination in AI Law (the “CO AI Law”). In addition, Colorado lawmakers have introduced SB 26-189, which would repeal and replace the CO AI Law with a narrower framework governing automated decision-making technology. The bill has already been passed by the Colorado House and Senate, and is being sent to Governor Polis who is expected to sign it.
With these developments, employers should be aware that the CO AI Law will not take effect on June 30, and seems unlikely to ever be implemented in its current form. Employers should continue to monitor this space and be prepared for the likely enactment of the CO AI Law’s replacement and for potential further litigation over the AI regulation in Colorado.
The Existing Law
The CO AI Law was signed in 2024, and is the most comprehensive AI law in the country. The law would impose a host of onerous requirements on employers, including implementation of risk management programs, impact assessments, annual reviews, and disclosures regarding algorithmic discrimination. Although it was supposed to go into effect on February 1, 2026, its effective date was postponed to June 30, 2026. For employers, the CO AI Law...
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