Colorado AI Act: Chatbot Disclosure and Rulemaking Timeline (2026-2027)
Colorado's SB 24-205 (the Colorado AI Act) is the first comprehensive US state AI law targeting high-risk AI systems. Signed May 2024, it takes effect February 1, 2026 for developers and February 1, 2027 for deployers. The Act covers AI systems making 'consequential decisions' in employment, education, financial services, healthcare, housing, insurance, and legal services.
In parallel, Colorado's chatbot transparency rules (aligned with the California-inspired bot disclosure framework) require any system interacting with consumers to disclose its non-human nature at first interaction — machine-readable marking is under active rulemaking at the Colorado Attorney General's office through 2026. Key timeline: (1) AG rulemaking proceedings: Q3-Q4 2026 for chatbot disclosure technical standards; (2) Developer compliance deadline: Feb 1 2026 (already passed — vendors in market should have documentation); (3) Deployer compliance deadline: Feb 1 2027 (next major wave of enforcement); (4) AG enforcement authority begins with pattern-or-practice investigations in 2027. For procurement officers: Colorado deployers of high-risk AI must complete impact assessments and maintain risk management policies by Feb 2027. The Council of AI verified measurement credential (DEFONEOS-SEAL) maps to the Colorado Act's documentation and measurement requirements, providing machine-readable attestation that a system has been measured against disclosure, fairness, and transparency criteria.
Standards and sources referenced
- Colorado SB 24-205 (Concerning Consumer Protections in Interactions with Artificial Intelligence Systems)
- Colorado Attorney General rulemaking notices (2026)
- Council of AI Verified Measurement Credential (DEFONEOS-SEAL)
- Colorado Revised Statutes Title 6, Article 1-1701 et seq.