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stating in his signing statement
webRelevant for tracking US state-level AI governance efforts; Colorado's law is among the first comprehensive state AI regulations and serves as a potential model or cautionary example for other jurisdictions.
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Importance: 55/100news articleanalysis
Summary
This Littler publication analyzes Colorado's SB 24-205, a landmark AI law requiring developers and deployers of high-risk AI systems to implement risk management practices and disclose AI use. The article covers the governor's signing statement expressing concerns and requesting legislative amendments, as well as the significant compliance burdens the law would impose on employers.
Key Points
- •Colorado's SB 24-205 imposes obligations on AI developers and deployers to protect consumers from algorithmic discrimination in high-risk AI systems.
- •Governor Polis signed the bill but issued a signing statement urging the legislature to significantly amend or replace the law before it takes effect in 2026.
- •The law creates substantial compliance requirements including risk assessments, impact statements, and disclosure obligations for employers using AI in consequential decisions.
- •The legislation applies to AI systems used in employment, housing, education, lending, and healthcare contexts.
- •Employers face uncertainty about implementation given the governor's reservations and the possibility of legislative revision before the 2026 effective date.
Cited by 1 page
| Page | Type | Quality |
|---|---|---|
| Colorado Artificial Intelligence Act | Policy | 53.0 |
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ASAP
ASAP
# Colorado’s Landmark AI Legislation Would Create Significant Compliance Burden for Employers Using AI Tools
By Niloy Ray, Zoe Argento, Philip Gordon, and Kellen Shearin
- May 16, 2024
- 14 minute read
_**ADDITIONAL UPDATE: On August 28, 2025, Colorado Governor Jared Polis signed an amendment to the Colorado AI Act (Senate Bill 24-205) that delays the law’s effective date to June 30, 2026. For more information,**_ [_**see our ASAP.**_](https://www.littler.com/news-analysis/asap/lawmakers-tee-colorado-ai-act-scaling-back-upcoming-legislative-session)
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_**UPDATE: On May 17, 2024, Colorado Governor Jared Polis signed Senate Bill 24-205 into law, although not without reservations. Governor Polis sent a letter to the members of the Colorado General Assembly encouraging them to reconsider and amend aspects of Senate Bill 24-205 before it takes effect on February 1, 2026. Notably, Governor Polis stated that the law deviated from the traditional method of addressing discrimination by subjecting the developer and deployer of the AI system to a negligence standard with respect to claims of discriminatory decision-making by an AI tool rather than targeting intentional discriminatory conduct. Further, Governor Polis expressed concerns over burdens to business from the complex compliance regime created by Senate Bill 24-205 and over the potential negative impact that Senate Bill 24-205, and other “patchwork” state-level governmental regulation, could have on the burgeoning technology. Governor Polis noted the need for a cohesive federal approach to regulating the use of AI and encouraged the General Assembly to work with stakeholders in an effort to amend Senate Bill 24-205 to “conform with evidence-based findings and recommendations for the regulation of this industry.”**_
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| - Colorado Senate Bill 24-205 ("SB205") introduces statutory tort liability for AI algorithmic discrimination in employment. If enacted, the bill would require employers using “high-risk” AI tools to implement risk management policies, conduct impact assessments, and provide detailed notices by February 1, 2026.<br>- Compliance with SB205 will place an onerous burden on any employer doing business in Colorado to identify “differential treatment or impact” on a broad list of protected categories. To comply with this duty, the bill requires extensive, and potentially costly, transparency, analysis, and documentation.<br>- If enacted, SB205 could stifle the use of AI by employers as it provides the right to appeal any adverse decision derived from the AI tool, including human review of the decision. The appeal requirement could not only minimize the speed and efficiency the AI tool is supposed to provi
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