Key point: During Colorado’s legislative special session, which aimed to address budgetary shortfalls resulting from this year’s federal appropriations act, lawmakers approved a delay in the Colorado AI Act’s effective dates.
Colorado lawmakers amended the Colorado AI Act, shifting the law’s effective date from February 1, 2026, to June 30, 2026. This delay applies to compliance obligations for developers and deployers of high-risk artificial intelligence systems. The amendment followed significant resistance from the technology and business communities, who are generally opposed to the original law. Whether the July 2025 White House AI Action Plan will provide further incentives or pressure on the legislature to revise the core obligations, as discussed here, is unclear.
For compliance professionals, the amendment provides a uniform extension to implement risk-management programs, conduct impact assessments, and prepare required disclosures, but the content and scope of these obligations remain unchanged. Organizations will still need to:
- Use reasonable care to avoid algorithmic discrimination
- Maintain detailed documentation, and
- Provide clear public statements about their AI systems and risk mitigation strategies.
Compliance and Legal teams should keep in mind that the law’s delegation of authority to the Attorney General to develop regulations remains substantively unchanged, as there was no deadline for the adoption of rules or regulations in the original text.
Bottom line: The delay provides developers, deployers (and legislators) with a few months of breathing room to comply with (or further amend) the obligations in the original law.
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