Policy Briefing — September 5, 2025
Colorado’s AI Act gives developers five months to deliver documentation that lets deployers complete mandatory impact assessments before the February 2026 effective date, demanding board-approved disclosure, monitoring, and vendor governance playbooks.
Executive briefing: Colorado Senate Bill 24-205 imposes impact assessment, disclosure, and risk management duties on deployers and developers of high-risk AI systems starting . By early September 2025, boards at developers must certify that technical documentation, model cards, and downstream support processes are in place so customers can satisfy their obligations. The statute requires developers to provide impact-assessment artefacts, summarise available systems on a public inventory, and share incident handling support.
Board governance checkpoints
- Documentation readiness. Validate that every high-risk system ships with the artefacts the law enumerates—training data summaries, intended use, prohibited use, monitoring guidance, and a contact path for deployers.
- Inventory transparency. Approve the public use-case inventory described in §6-1-1704(4), ensuring marketing and legal teams align messaging with actual controls.
- Escalation support. Require policies for responding to deployer notices of algorithmic discrimination, including investigation steps, timeline commitments, and board reporting.
Operational priorities for developers
- Impact assessment kits. Package model cards, dataset cards, bias testing results, and integration guidance so deployers can complete §6-1-1703 impact assessments without ad-hoc support.
- Change management. Track intentional and substantial modifications defined in §6-1-1702(10) so new risks trigger refreshed documentation and notifications.
- Third-party oversight. Map subcontractors and pre-trained components feeding high-risk systems, documenting their compliance representations for deployer due diligence.
Enablement moves
- Coordinate sales, customer success, and legal teams on the statutory definition of high-risk so contract scoping aligns with Colorado’s consumer-impact categories.
- Integrate AI governance dashboards into board packs showing documentation completion rates, incoming deployer queries, and outstanding remediation items.
- Offer training sessions for customers’ compliance leads demonstrating how provided artefacts map to Colorado’s reporting and mitigation requirements.
Zeph Tech helps AI developers operationalise Colorado’s SB24-205 obligations—building documentation pipelines, response protocols, and board-level reporting.