Colorado AG Proposes New AI Disclosure Regime

The Colorado Attorney General proposed rules to implement the state's new Automated Decision-Making Technology ("ADMT") Act, shifting the regulatory framework for AI from mandatory risk management to transparency and consumer disclosure.

In the proposal, the Attorney General outlined compliance obligations for developers and deployers of automated systems used in consequential decisions. That statute repealed and reenacted, with amendments, the 2024 Colorado AI Act, also known as the Consumer Protections for Artificial Intelligence Act (see prior coverage).

Developers of covered automated decision-making technology would be required to provide deployers with technical documentation detailing intended uses, known limitations, and training data categories. Developers would also need to retain compliance records for at least three years.

Deployers would need to provide consumers with clear notice before using the technology in decisions affecting education, employment, housing, lending, healthcare, government benefits, and insurance. If a decision results in an adverse outcome, deployers would be required to notify the consumer within 30 days and explain their right to request human review.

Under the ADMT Act, the Attorney General has exclusive enforcement authority and must offer a 60-day cure period before enforcement until January 1, 2030, unless a violation is knowing or repeated. The act, which takes effect on January 1, 2027, creates no new private right of action and apportions liability between developers and deployers based on relative fault in discrimination actions.

The draft rules also implement provisions of the Colorado Chatbot Safety Act.

Comments are due by October 26, 2026.