By Mitchell Chamberlin
In early 2024, the Colorado state legislature passed Senate Bill 24-205, Consumer Protections for Interactions with Artificial Intelligence Systems (CPIAIS), which was signed into law by Governor Jared Polis on May 17, 2024. After he signed the bill, which is set to go into effect on February 1, 2026, Governor Polis issued a letter to the Colorado legislature expressing support for the purpose of the bill and concerns he has regarding the implementation of the first-of-its-kind law.
Among his concerns was the potential for this law to stifle innovation in the state and complicate a patchwork of compliance obligations for developers of artificial intelligence (AI) tools being deployed in Colorado. The letter also includes a directive to use the time between the passage of the bill and implementation of the law to “…fine tune the provisions and ensure that the final product does not hamper development and expansion of new technologies in Colorado…”
Nearly a year later on May 5, 2025, Governor Polis and other leading officials in Colorado issued another letter to the Colorado General Assembly. With hours left in the 2025 legislative session, the letter requested that the legislature take action to delay the implementation of CPIAIS until January of 2027 to allow more time for stakeholders to “…collaborate on a balanced, future-ready framework” that “…protects privacy and fairness without stifling innovation or driving business away…” from Colorado.
Legislative Maneuvers to Alter Bill and Delay Implementation Fail
As part of the Governor’s requested “fine tuning” of CPIAIS, the Colorado General Assembly proposed Senate Bill 25-218. This bill included redefining the definition of “algorithmic discrimination," easing of requirements for AI developers, modifications to the timing of required impact assessments, and changes to disclosure and documentation requirements. However, the bill was postponed indefinitely before eventually being killed by its sponsor.
The General Assembly also attempted to include an amendment to delay the implementation of CPIAIS in an unrelated bill. However, that bill was effectively filibustered until the end of the legislative session and a vote did not take place.
Law Set to Take Effect on February 1, 2026
The law, which has sweeping requirements regarding the implementation of AI tools across many applications, including for decision-making in employment, is set to go into effect as scheduled on February 1, 2026. However, the Governor could call a special legislative session to alter CPIAIS, or a new bill could be introduced in the next legislative session (which starts in January of 2026) to modify or replace it. As of now, employers should consider making preparations to comply with CPIAIS.
DCI will continue to monitor developments on this law and will publish new blogs as needed.
