Is the Colorado AI Act still happening?

Not in its original form. The legislature repealed and replaced it in May 2026 with SB 26-189, which keeps consumer-facing notice and disclosure duties for automated decision-making technology and drops the duty of care, impact assessments, and risk programs.

Do I have any Colorado disclosure obligation right now?

No — no Colorado AI-disclosure obligation is in force before January 1, 2027. The practical move is to adopt the disclosure pattern now anyway, since it is the same one the EU AI Act and California and Utah law already expect.

What will SB 26-189 require from a chatbot?

A disclosure presented to the consumer in the interaction itself, on every consumer-facing surface where the bot is deployed, with records retained in case of an Attorney General inquiry. Details will be shaped by the Attorney General's rulemaking before the effective date.

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Colorado after the AI Act: the SB 26-189 disclosure framework

Colorado SB 26-189 (2026), automated decision-making technology framework (repealing and replacing the Colorado AI Act, SB 24-205)

Updated July 20, 2026

If a vendor or an article tells you Colorado requires chatbot disclosure today, they are working from last year's news. The Colorado AI Act (SB 24-205) never took effect: its start date was pushed to June 30, 2026, it drew a constitutional challenge in April 2026, and in May 2026 the legislature repealed and replaced it with SB 26-189 — a much narrower framework focused on notice and disclosure duties for automated decision-making technology used with consumers.

The replacement takes effect January 1, 2027. Consumer-facing AI disclosure survives in this narrower form; the duty of care, impact assessments, and risk programs from the original Act were removed. Nothing is in force in 2026 — but the disclosure pattern the 2027 framework expects is the same one the EU and other US states already require, so getting it in place now costs nothing extra.

When it applies

Takes effect January 1, 2027. The original Colorado AI Act was repealed and replaced in May 2026; no Colorado AI-disclosure obligation is in force before then.

The obligation

Colorado's replacement framework narrows the original AI Act to notice and disclosure duties for automated decision-making technology used with consumers. Consumer-facing AI disclosure survives in this narrower form; the duty of care, impact assessments, and risk programs were removed.

The disclosure pattern it expects

A disclosure presented to the consumer in the interaction itself. Disclosed's badge plus first-message notice covers the interaction-disclosure pattern ahead of the 2027 date.

Readiness checklist

Consumers are told they are talking to an AI system when the interaction starts.
The disclosure covers every consumer-facing surface where the bot is deployed.
Disclosure records are retained in case of an Attorney General inquiry.
The setup is reviewed against the Attorney General's rulemaking before January 1, 2027.

Common questions

Is the Colorado AI Act still happening?: Not in its original form. The legislature repealed and replaced it in May 2026 with SB 26-189, which keeps consumer-facing notice and disclosure duties for automated decision-making technology and drops the duty of care, impact assessments, and risk programs.
Do I have any Colorado disclosure obligation right now?: No — no Colorado AI-disclosure obligation is in force before January 1, 2027. The practical move is to adopt the disclosure pattern now anyway, since it is the same one the EU AI Act and California and Utah law already expect.
What will SB 26-189 require from a chatbot?: A disclosure presented to the consumer in the interaction itself, on every consumer-facing surface where the bot is deployed, with records retained in case of an Attorney General inquiry. Details will be shaped by the Attorney General's rulemaking before the effective date.

Related guides

See also the other jurisdictions: EU AI Act, Article 50(1) · Utah AI Policy Act · California B.O.T. Act

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Disclosed provides compliance tooling and records; this document is not legal advice. Review it with your counsel before relying on it.