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ARTICLE · 22 SEPTEMBER 2025

Colorado's AI Act: Implementation Delayed

Moore & Van Allen, PLLC
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In 2024, Colorado enacted the Colorado Artificial Intelligence Act, establishing the nation's most comprehensive state-level frameworks for regulating high-risk AI systems.

United StatesTechnology
Tandy B. Mathis
Tandy B. Mathis

In 2024, Colorado enacted the Colorado Artificial Intelligence Act, establishing the nation's most comprehensive state-level frameworks for regulating high-risk AI systems. The law applies to AI used in consequential decision-making such as housing, employment, healthcare, education, and financial or lending services. The law was originally scheduled to take effect on February 1, 2026. However, recent legislative developments have altered that timeline and raised questions about the law's future scope and implementation.

On August 26, 2025, the Colorado General Assembly passed SB25B-004, formally delaying the effective date of the AI Act to June 30, 2026. Governor Jared Polis signed the bill into law August 28, 2025. The amendment is the sole outcome of a special legislative session convened by the Governor to address both fiscal issues and mounting concerns from industry stakeholders regarding the law's complexity and anticipated compliance costs.

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