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Colorado Delays Enforcement of AI Act (SB 25B-004)
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Relevant to AI governance practitioners tracking US state-level AI regulation; Colorado's AI Act was a pioneering state law, and this enforcement delay signals ongoing challenges in translating AI policy into practice.
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Importance: 42/100news articlenews
Summary
This Paul Hastings client alert covers Colorado's SB 25B-004, which delays enforcement of Colorado's AI Act (SB 24-205). The original AI Act imposed obligations on developers and deployers of high-risk AI systems, and this subsequent legislation pushes back the enforcement timeline, giving businesses more time to comply with the state's AI governance requirements.
Key Points
- •Colorado signed SB 25B-004 to delay enforcement of its landmark AI Act (SB 24-205), which regulated high-risk AI systems.
- •The original Colorado AI Act imposed duties on AI developers and deployers regarding transparency, risk management, and consumer protections.
- •The enforcement delay reflects ongoing industry and legislative debate about readiness and practical implementation challenges.
- •Colorado's AI Act was one of the first comprehensive state-level AI governance laws in the US, making this delay significant for AI policy watchers.
- •Businesses operating in Colorado with AI systems should monitor revised compliance deadlines and adjust implementation timelines accordingly.
Cited by 1 page
| Page | Type | Quality |
|---|---|---|
| Colorado Artificial Intelligence Act | Policy | 53.0 |
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Colorado Delays Enforcement of AI Act | Paul Hastings LLP left-caret Insights Client Alerts
Colorado Delays Enforcement of AI Act
September 03, 2025
By Amir R. Ghavi , Katie Katsuki and Howard Glucksman
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On August 28, Colorado Gov. Jared Polis signed SB4, delaying the effective date of the Colorado AI Act (CAIA) from February 1, 2026, to June 30, 2026. Earlier this summer, Gov. Polis called the Colorado Legislature into a special session on the CAIA in an effort to reduce its fiscal impact on the state of Colorado, which is facing a $750 million budget shortfall.
This special session came shortly after the release of President Donald Trump’s AI Action Plan , which urges the federal government to avoid supporting states that impose burdensome AI regulations. While it respects states’ rights to pass reasonable laws, it recommends only providing federal AI-related funding to states whose regulatory environments do not stifle innovation.
Although Colorado lawmakers considered broader changes to the CAIA — such as reducing the scope of required disclosures by AI developers and deployers, curtailing certain consumer rights provisions and establishing a framework of joint and several liability for AI developers and deployers — they were unable to reach an agreement.
The CAIA regulates AI systems used to make or facilitate consequential decisions, such as those pertaining to healthcare, employment and essential government services, which it defines as “high-risk AI systems.” Developers and deployers of high-risk AI systems will be required to make certain disclosures about:
How the AI systems are used
How the AI systems were developed
How risks of algorithmic discrimination are measured and mitigated
The CAIA also gives Colorado consumers certain protections, including:
The right to be notified before a decision is made using a high-risk AI system
The right to correct incorrect personal data used in AI decision-making
The right to appeal adverse consequential decisions made by a high-risk AI system
The CAIA will be enforced by the Colorado attorney general. Violations will be treated as unfair trade practices, subject to a penalty of up to $20,000 per violation.
The Paul Hastings AI practice is closely monitoring updates to the CAIA. If you have any questions, please do not hesitate to contact any member of our team.
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Contributors
Amir R. Ghavi Partner, Corporate Department
Email New York: +1-212-318-6725 Katie Katsuki Associate, Corporate Department
Email New York: +1-212-318-6952 Howard Glucksman Associate, Corporate Department
Email New York: +1-212-318-6666 Practice Areas
Technology Transactions
For More Information
Amir R. Ghavi Partner, Corporate Department
Email New York
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