Colorado: AI law takes effect January 1, with draft rules now out

What changed

Colorado’s rewritten AI law, SB 26-189, takes effect January 1, 2027 whether or not the rules are final. The law requires you to tell applicants and employees when covered software materially influences an employment decision, explain an adverse decision within 30 days, and offer human review on request where commercially reasonable. Draft rules filed August 11 fill in the details.

What to do

Inventory the hiring and promotion tools that score or rank people automatically, and flag those that materially influence a decision. Draft the applicant and employee notice, the 30-day adverse-decision explanation, and a human-review process; adjust when the final rules land.

Primary source: Colorado Attorney General, August 11, 2026. Part of Compliance Watch, Issue 01 (September 11, 2026). Last reviewed September 11, 2026.

Questions about this update?

Every “What to do” line above is a task for someone at your company. Our clients hand the payroll and tax pieces to us and get an HR advisor for the rest.

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