Colorado Enacts Landmark AI Legislation

On May 17, 2024, Colorado Governor Jared Polis signed into law SB24-205 — Consumer Protections for Artificial Intelligence (Colorado AI Act) — making Colorado as the first state to adopt broad artificial intelligence (AI) legislation. While other states have enacted AI-specific legislation, including a new law in Utah that establishes disclosure requirements for certain uses of generative AI, the landmark Colorado AI Act more broadly establishes requirements for developers and deployers of "high-risk artificial intelligence systems," as well as disclosure requirements for AI systems that are intended to interact with consumers.

The new law is notable not just as a "first" in AI regulation in the United States, but also in its level of complexity: it establishes a range of detailed obligations for AI developers and deployers. The Colorado AI Act also gives the state's Attorney General (AG) plenary rulemaking authority, pointing to even more detailed regulations to