Fractional CHRO
CAIA Assessment
Colorado AI Act (SB 24-205)
A comprehensive guide for HR and people operations leaders navigating high-risk AI regulation in Colorado.
Do you need to comply? Use our Colorado SB 24-205 Statutory Risk Assessment Tool. This is a free compliance risk assessment for Colorado Employers with 50 or more employees.
Overview
What This Law Is
The Colorado AI Act regulates how high-risk AI systems are built and used in Colorado. It focuses on systems that affect people's rights and opportunities.
Hiring decisions. Promotion pathways. Performance management systems. Terminations. Educational access. Housing approvals. Lending decisions.
All are in scope under this legislation.
The law centers on one critical objective: preventing harm from automated decisions before it happens.
Hiring & Recruiting
Resume screening, candidate ranking, interview scoring systems
Workforce Decisions
Promotion recommendations, performance analytics, termination risk models
Access & Opportunity
Education placement, housing approval, credit and lending decisions
Applicability
Who It Applies To
You are likely covered if you meet any of these criteria:
HR Technology Users
Use AI in recruiting, screening, or hiring processes
Deploy AI for performance scoring or promotion decisions
Software Purchasers
Buy HR tech platforms that include AI-driven recommendations
License third-party tools with algorithmic decision-making
AI Developers
Develop or deploy AI tools used on Colorado residents
Create decision systems affecting protected opportunities
Colorado Employers
Operate business locations in Colorado
Employ Colorado-based workers or contractors

Important: You do not need to be an AI company to be affected by this regulation. Traditional employers using AI tools fall under compliance requirements.
Requirements
What The Law Requires
If you use high-risk AI systems, you must demonstrate these five core compliance areas:
01
Risk Management
You actively assess and mitigate foreseeable risks like bias and discrimination. Regular audits required.
02
Impact Assessments
You document how AI systems affect individuals and protected classes. Track disparate impacts.
03
Transparency
You disclose when AI is used in covered decisions. Explain its role clearly to affected individuals.
04
Accountability
You can explain decisions made by AI systems. Respond effectively to complaints or audits.
05
Vendor Oversight
You understand what your vendors' AI systems do. Know where risks sit in your technology stack.
Updates
What Changed Recently
Enforcement was delayed from February 1, 2026 to June 30, 2026.
Nothing else changed in the regulation.
This is not a pause on compliance obligations. It provides extra time to prepare your systems and processes.
1
Original Date
February 1, 2026
2
Revised Date
June 30, 2026
3
Your Action Window
Use this time wisely

Planning Tip: Organizations should treat the original February date as their internal deadline to ensure readiness well before enforcement begins.
Impact
Why Business Owners, Executives and HR Leaders Should Care
Most AI risk lives in HR long before legal teams identify exposure.
1
Job Descriptions
Language generation and optimization tools
2
Resume Screening
Automated candidate filtering and ranking
3
Interview Scoring
AI-powered assessment and evaluation systems
4
Performance Management
Predictive analytics and rating algorithms
5
Workforce Analytics
Planning tools with automated recommendations
If you cannot explain how decisions are made, the company carries the risk.
Clear documentation and explainability are not optional. They are foundational to compliance and risk mitigation.
Services
How I Help
I work with leaders to make compliance practical, not theoretical.
AI System Mapping
Mapping where AI is actually used across HR functions and workflows
Risk Identification
Identifying high-risk tools and decision points requiring immediate attention
Vendor Review
Reviewing vendors through a compliance lens with clear risk assessments
Documentation
Building simple documentation that holds up under scrutiny and audits
Leadership Training
Training leaders on responsible AI use and ethical decision-making frameworks
Process Design
Creating defensible, human-centered processes that balance automation with oversight
No fear tactics. No overengineering. Just clarity and actionable guidance.
The Goal
Use AI Where It Helps
Leverage technology to improve efficiency and reduce bias in decision-making processes
Protect People Where It Can Harm
Build safeguards that prevent discriminatory outcomes and preserve individual rights
Stay Ahead of Enforcement
Implement proactive compliance measures without scrambling when deadlines approach
Strategic AI governance balances innovation with responsibility. Organizations that prepare now will have competitive advantage and reduced legal exposure.