Colorado’s Department of Law opens its formal rulemaking hearing on the ADMT Act (SB 26-189) and the Chatbot Safety Act (HB 26-1263) at 10:00 a.m. in Denver today, with written comments closing at 11:59 p.m. MST. Zoom access is available by registration through the AG’s office. Both laws take effect January 1, 2027, and DOL has declined to add a formal enforcement grace period.

SB 26-189 repealed and reenacted the 2024 Colorado AI Act, imposing duties on developers and deployers of automated decision-making technology used to materially influence consequential decisions. HB 26-1263 layers on age-estimation, AI-disclosure, minor-protection, and annual reporting obligations for chatbot operators. DOL filed initial draft rules on August 11, released an interim draft on October 6 after more than sixty comments, and published a regulatory analysis on October 21.

The interim draft’s New Rule 6 is where the leverage sits. According to Ballard Spahr’s read, Rule 6 presumes an ADMT output materially influences a decision if it constrains options, sets a threshold, or produces a score, rank, or recommendation consistent with the outcome. Deployers can rebut by showing a “de minimis factor,” such as a hard cut-off threshold. Adverse-outcome disclosures were scaled back: deployers must describe the ADMT’s specific role and respond to consumer follow-up requests within 15 days, and ECOA and FCRA notices can carry Colorado’s information on a supplemental page. Enforcement discretion, DOL has signaled, will focus on “egregious and intentional” violations.

For a 5-to-30-person shop running AI lead scoring, chatbot qualification, or automated application review in any covered sector, the practical read is to assume coverage and plan deployer duties now. The presumption runs against you; the rebuttal is yours to build.

Rulemaking windows don’t reopen. Whatever lands in the final text before January 1 is what deployers inherit.

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