AI Governance Briefing — October 9, 2025

Executive briefing: Colorado’s SB24-205 mandates deployers of high-risk AI systems to complete annual impact assessments that evaluate algorithmic discrimination risks, document mitigation steps, and inventory data sources. Zeph Tech is running joint pilots with Colorado customers—populating assessment templates, testing data-correction workflows, and verifying that notices and appeals processes align with the statute before the February 1, 2026 effective date.

Statutory checkpoints

Impact assessment contents. Section 6-1-1706 requires deployers to capture system purpose, data inputs, evaluation metrics, mitigation measures, and governance approvals.
Annual cadence. Assessments must be refreshed at least annually and whenever the system undergoes substantial modification.
Record retention. Deployers must retain impact assessments and related documentation for three years and make them available to the Attorney General upon request.

Control alignment

Risk management mapping. Align assessment fields with NIST AI RMF Map and Measure functions so metrics, harms, and mitigations align with enterprise risk registers.
Privacy integration. Synchronise Colorado assessments with GDPR/CCPA data subject rights processes to streamline correction and appeal handling.

Detection and response priorities

Test model monitoring dashboards that flag disparate impact indicators and feed directly into the assessment documentation.
Validate consumer notice templates and appeal workflows so they meet Section 6-1-1706 transparency duties.
Stage mock Attorney General inquiries to ensure records can be produced quickly with supporting evidence.

Enablement moves

Deliver training sessions for Colorado customer teams on completing Zeph Tech’s co-developed assessment template.
Embed assessment checkpoints in software development lifecycle gates for features slated for Colorado deployment.
Coordinate with legal to track evolving Attorney General rulemaking that may refine assessment content.