Governance Briefing — August 19, 2025

Executive briefing: Colorado SB24-205 (the Colorado Artificial Intelligence Act) applies to deployers and developers of high-risk AI systems beginning 1 February 2026. Deployers must implement risk management policies, complete impact assessments before deployment and after major changes, provide consumer notices when consequential decisions are automated, and register with the Attorney General within 90 days of deployment.

Key governance checkpoints

Risk management program. Establish written policies covering risk identification, mitigation, and monitoring aligned with NIST AI RMF or ISO/IEC 42001, as referenced in §6-1-1704.
Impact assessments. Develop templates capturing system purpose, training data provenance, performance metrics, discrimination testing, and safeguards for appeal rights.
Incident escalation. Define processes for reporting algorithmic discrimination to the Attorney General within 90 days of discovery.

Operational priorities

Inventory and classification. Catalog all AI systems influencing employment, housing, credit, insurance, or healthcare decisions, and label those that meet the statute’s high-risk definition.
Consumer-facing notices. Draft disclosures explaining automated decision use, data categories, opt-out or appeal rights, and human review pathways.
Developer coordination. Secure documentation from AI developers covering intended uses, limitations, and mitigation guidance to fulfill deployer obligations.

Enablement moves

Create dashboards tracking assessment completion, mitigation actions, and registration deadlines across business units.
Conduct bias and robustness testing workshops with data science teams to evidence ongoing monitoring.

Sources

Zeph Tech operationalizes Colorado AI Act compliance with inventory intelligence, impact assessment blueprints, and consumer notice tooling.