Gov. Jared Polis signed SB 26-189 on May 14, 2026, killing the 2024 Colorado AI Act roughly six weeks before it would’ve taken effect and ending the brief life of the country’s first comprehensive state AI statute. The replacement framework, an Automated Decision-Making Technology disclosure regime, takes effect Jan. 1, 2027.

The vote wasn’t close. SB 26-189 cleared the Senate 34-1 and the House 57-6, margins Troutman flagged as a near-unanimous retreat by the same legislature that had positioned Colorado as the regulatory vanguard a year earlier.

What’s gone matters as much as what stays. Morrison Foerster notes that the duty of reasonable care, mandatory risk management programs, and annual impact assessments are eliminated. Holland & Knight points out the terminology rewrite that does most of the work: “high-risk AI system” becomes “Automated Decision-Making Technology,” and SB 205’s “substantial factor” test is swapped for a softer “materially influence” standard.

The covered domains, employment, education, lending, financial services, insurance, healthcare, and essential government services, are unchanged. Developers must document intended and harmful uses, disclose training data categories, and retain records at least three years. Deployers owe consumers clear notice before ADMT materially influences a consequential decision, and post-adverse-outcome rights to correct data and request human review where commercially reasonable. HIPAA-covered entities, ECOA/FCRA-compliant creditors, and FDA-regulated devices get carve-outs.

Enforcement sits exclusively with the Colorado AG. There’s no private right of action, and a 60-day cure window applies unless violations are knowing or repeated. The AG must finalize rules on disclosures and consumer rights before the Jan. 1, 2027 effective date, which is where the real fight migrates. Compliance tooling vendors including LemonLime are already mapping the ADMT obligations for hiring and lending stacks.

The first-mover state blinked first. The hard rules now live in rulemaking, not statute.

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