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ARTICLE · 10 NOVEMBER 2026

Automated Decisions: State Requirements And Federal Challenges

Barnes & Thornburg LLP
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State AI laws in California and Colorado establish compliance deadlines beginning January 2027 for automated decision-making systems, while federal challenges and EU AI Act amendments create additional complexity for legal teams. Federal intervention has temporarily limited Colorado's enforcement authority, and the EU has revised its implementation timeline with certain prohibitions taking effect in December 2026. Organizations must navigate overlapping requirements for AI systems involved in consequential

United StatesMedia, Telecoms, IT, Entertainment
Brian McGinnis
Brian McGinnis
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This is part three of a four-part series highlighting key learnings from the IAPP Privacy. Security. Risk. + AI Governance Global conference.

State AI Laws: Compliance Deadlines and Requirements

The compliance calendar for automated decision-making is another area in which legal teams face near-term decisions. California's automated decision-making technology (ADMT) requirements have a Jan. 1, 2027 compliance date for existing covered uses in significant decisions involving employment, housing, education, financial services, and healthcare.

The regulations focus on technologies that replace or substantially replace human decision-making. A qualifying human reviewer must understand and evaluate the output, consider relevant information, and have authority to change the decision.

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