AI controls
Colorado: the date, and the controls that answer it
SB 26-189 takes effect on 1 January 2027.
The dates
Colorado’s replacement artificial intelligence law, SB 26-189, takes effect on 1 January 2027. For a company that deploys an AI system in a consequential decision about a Colorado resident (employment, lending, housing, insurance, health care, education), it is a notice, explanation, appeal and recordkeeping regime: tell the person an AI system was used, explain an adverse decision, give them a way to appeal to a human, and keep the records that show you did.
The control test
The control test: an inventory of every system that makes or shapes a consequential decision about a Colorado resident; a control for each of the four duties, with an owner, a frequency and the evidence it leaves; a test of each control against a sample of real decisions, the way a financial reporting control is tested; and a record set that answers the Attorney General’s questions in the order they will be asked. You receive the inventory, the control matrix, the test workpapers and a gap list with an owner and a date on every line, in time for 1 January 2027.
Send the date on your calendar and a sentence on what is coming up.
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