Colorado’s Attorney General opens the formal rulemaking hearing on 4 CCR 904-6 at 10:00 AM today, with written comments on the ADMT Act (SB 26-189, signed May 2026) and the Chatbot Safety Act (HB 26-1263, signed July 1, 2026) closing at 11:59 PM MST. Both statutes take effect January 1, 2027. Neither carries a small-business exemption.
The unresolved question is whose compliance obligation this actually is. Ballard Spahr notes the role of ADMT vendors in multiparty arrangements is explicitly flagged for today’s discussion. “Midstream developers” integrating third-party models would’ve to pass upstream documentation downstream to deployers, which in plain English means the small business running the AI.
The draft rules aren’t light. Under proposed Rule 6.2, adverse-outcome disclosures must go out within 30 days through at least two communication methods. Rule 7.7 requires meaningful human review within 45 days, by a reviewer independent of the original decision-maker and barred from using ADMT to assist. Deployers must confirm consumer requests within 10 days. ECOA and FCRA adverse-action notices only partially satisfy the Colorado requirement, and only if ADMT-specific content is layered in.
Industry pushback has been pointed. In its September 10 comment letter, the U.S. Chamber of Commerce’s C_TEC, led by Senior Vice President Jordan Crenshaw, argued the draft definitions of “ADMT,” “Materially Influence,” and “Consequential Decision” are broader than California’s CCPA ADMT regulations, Connecticut’s ADMT law, and GDPR Article 22, and warned of “no implementation runway.”
That runway question is the one owners using AI outreach, lead-scoring, or chatbot services should track closely. Services like LemonLime prepare customer-growth work proactively; whether the disclosure duty attaches to the vendor or the deployer is precisely what today’s hearing will decide. We covered the stakes six days ago and when the comment window first opened.
Sixty-seven days until the statute binds. The rules writing it are still in motion.
Sources
- https://coag.gov/ai/
- https://www.akingump.com/en/insights/ai-law-and-regulation-tracker/colorado-attorney-general-releases-interim-draft-rules-implementing-admt-and-chatbot-safety-acts
- https://www.wiley.law/alert-Colorado-Proposes-Detailed-Rules-Implementing-New-ADMT-and-Chatbot-Laws
- https://www.consumerfinancialserviceslawmonitor.com/2026/08/colorado-proposes-rules-for-automated-decision-making-technology-and-chatbot-safety/
- https://www.uschamber.com/technology/comments-on-proposed-rules-implementing-the-automated-decision-making-technology-act-sb-26-189-and-the-conversational-artificial-intelligence-services-act-hb-26-1263-4-ccr-904-6