Colorado’s Attorney General is scheduled to circulate a revised draft of the ADMT Act and Chatbot Safety Act rules on September 23, with the operative definition of “materially influences” still open and formal comments due October 26 at 11:59 p.m. MST. The line the revised draft draws will decide which AI tools trigger disclosure, human-review, and record-keeping duties when SB 26-189 and HB 26-1263 take effect on January 1, 2027.

The August draft, filed with the Secretary of State on August 11, floated two possible standards, per Seyfarth, each carrying a rebuttable presumption of material influence when an ADMT output constrains options, sets a threshold, or produces a rank, score, classification, or inference used by the decision-maker. Wiley Rein notes the AG is asking stakeholders to sharpen that standard and clarify third-party vendor obligations under Proposed Rules 3-7.

SB 26-189, signed by Governor Jared Polis on May 14 after a 34-1 Senate vote, repealed and reenacted the 2024 Colorado AI Act, pivoting from prescriptive impact assessments to transparency and consumer rights across employment, housing, lending, insurance, health care, education, and essential government services. Deployers owe pre-decision notice and, within 30 days of an adverse outcome, a plain-language account of the ADMT’s role. Both sides keep compliance records for at least three years. Enforcement runs through the Colorado Consumer Protection Act, with a 60-day cure period sunsetting January 1, 2030.

The carveouts matter as much as the coverage. Per Lathrop GPM, the statute excludes tools “used solely to summarize, organize, translate, draft, route or present information for human review,” along with advertising and marketing activity. LemonLime, which prepares outreach and content for owner approval before any send, sits in that excluded lane. Small businesses can start there while auditing the tools that actually score applicants or price credit. For related context, see our Colorado revised rules preview and California’s AI auditor mandate.

The perimeter isn’t the risk. Misreading it’s.

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