The Colorado Attorney General’s formal rulemaking hearing on SB 26-189 and HB 26-1263 convenes at 10:00 AM today in Denver and on Zoom, and written comments close at 11:59 PM MT. After tonight, the record closes and the text that governs any business whose AI “materially influences a consequential decision” starts hardening into the rules that take effect January 1, 2027.

The procedural runway has been short on purpose. The AG filed proposed rules on August 11, collected more than sixty comments by September 4, released an interim draft on October 6, and posted its regulatory analysis on October 21 (per Akin Gump and the AG’s page). Each round narrowed the drafting latitude. Today is the last structured input before the stack locks.

The coverage threshold is the whole fight. Gibson Dunn’s read of the deployer duties, pre-use notice, a plain-language explanation within 30 days of an adverse outcome, and human review on request, pulls in software most small businesses don’t think of as regulated: AI lead scoring, chatbot qualification, automated outreach prioritization touching Colorado consumers. That’s the practical surface area to map now, as our earlier preview of the hearing laid out.

One wrinkle shadows all of it. Enforcement of the ADMT Act is currently stayed in federal district court in xAI v. Weiser, with a preliminary injunction ruling due 28 days after the rules finalize. Morrison Foerster frames the architecture as two regimes, ADMT and chatbots.

The pattern is familiar from TARP-era rulemaking and the Section 230 debates: the fastest compliance pressure arrives before any court decides whether the regime stands.

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