AI Governance Briefing — October 18, 2025
Zeph Tech details the final-quarter readiness sprint for Colorado’s Artificial Intelligence Act before the February 2026 effective date.
Executive briefing: Colorado’s Consumer Protections for Artificial Intelligence Act (SB24-205) takes effect on February 1, 2026. Developers and deployers now have one quarter to certify that their high-risk AI systems cannot cause algorithmic discrimination, document impact assessments, and prepare to notify both consumers and the Attorney General when incidents occur. Zeph Tech is sequencing Colorado-specific runbooks that reconcile state obligations with NIST AI RMF profiles and ISO/IEC 42001 controls.
Key statutory duties
- Risk management programmes. Developers and deployers of high-risk AI systems must implement and document reasonable risk management policies that identify, test, and mitigate algorithmic discrimination, drawing on recognised frameworks such as the NIST AI RMF.
- Impact assessments and transparency. Before deploying or substantially modifying a high-risk AI system, organisations must complete impact assessments that inventory data, evaluate potential discrimination, and explain mitigation; developers must furnish deployers with documentation detailing system purpose, training data limitations, and known risks.
- Consumer notice and reporting. Deployers must provide clear notice when high-risk AI is used to make consequential decisions, allow individuals to correct inaccurate data, and report incidents of algorithmic discrimination to the Attorney General within 90 days.
Operational priorities
- Map consequential decisions. Catalogue employment, lending, housing, healthcare, insurance, education, and essential government-service use cases to determine which AI systems fall under Colorado’s high-risk definition.
- Integrate assessments into release gates. Embed Colorado-specific checklists into model governance workflows so every high-risk AI change ships with documented testing, reviewer sign-off, and mitigation evidence.
- Stand up incident reporting pipelines. Align detection, legal, and customer-relations teams on how to triage suspected algorithmic discrimination, compile notification packets, and deliver reports to the Colorado Attorney General within statutory timelines.
Enablement moves
- Deliver targeted training for product, risk, and legal partners that contrasts Colorado’s requirements with emerging state laws (e.g., Connecticut, Tennessee) to harmonise playbooks.
- Update vendor diligence questionnaires so third-party AI suppliers attest to Colorado compliance, share impact assessment templates, and agree to pass-through notification clauses.
- Instrument dashboards that trace safe-harbour alignment (NIST AI RMF, ISO/IEC 42001) and track remediation progress heading into the February 2026 enforcement window.
Sources
- Colorado General Assembly — SB24-205 (Consumer Protections for Artificial Intelligence Act)
- State of Colorado — Signed SB24-205 (2024 Session Laws)
- Colorado Attorney General — Notice of Proposed Rulemaking for the AI Act (September 2024)
Zeph Tech equips teams with Colorado AI Act compliance kits that fuse risk assessments, incident playbooks, and safe-harbour controls.