AI Governance Briefing — October 2, 2025
Zeph Tech is auditing developer deliverables under Colorado’s Artificial Intelligence Act so documentation, risk statements, and incident commitments reach deployers before the February 2026 effective date.
Executive briefing: Colorado’s SB24-205 makes high-risk AI developers responsible for documented risk management, transparency, and incident cooperation. Section 6-1-1705 requires developers to exercise reasonable care to prevent algorithmic discrimination and to provide deployers with comprehensive system documentation, training-data limitations, and mitigation plans. Zeph Tech is running an October audit to confirm every Colorado-relevant model has the mandated disclosures, impact assessment templates, and Attorney General reporting commitments baked into commercial agreements.
Statutory checkpoints
- Reasonable care duty. Developers must implement risk management policies and oversight processes that reduce algorithmic discrimination, aligning with recognised frameworks.
- Documentation packages. Section 6-1-1705(2) obliges developers to share system descriptions, intended uses, limitations, and known risks with deployers so they can meet their own compliance obligations.
- Incident support. Developers must notify deployers of material updates and assist with investigations and notices when algorithmic discrimination occurs.
Control alignment
- NIST AI RMF integration. Map Colorado’s reasonable care duty to Govern 1 accountability structures and Manage 3 incident response, ensuring responsibilities are traceable.
- Contract governance. Update licensing and support agreements with Colorado-specific addenda covering documentation delivery, notification timelines, and liability allocation.
Detection and response priorities
- Inventory high-risk AI models sold or supported in Colorado and verify each has an attested documentation bundle aligned to Section 6-1-1705.
- Establish monitoring that flags changes to training data, model purpose, or mitigation controls so updated disclosures reach deployers within agreed service windows.
- Test joint incident playbooks with deployers to ensure Colorado Attorney General notifications can be filed within the statutory 90-day window.
Enablement moves
- Brief sales and customer success teams on Colorado-specific deliverables so contracts signed in Q4 2025 include the required documentation commitments.
- Provide deployers with updated impact assessment templates and risk mitigation guidance tailored to Colorado’s definitions of algorithmic discrimination.
- Schedule executive reviews of Colorado compliance progress alongside EU AI Act reporting to maintain a global AI governance dashboard.