HR Updates · Updated September 15, 2026
AI and automated tools are already part of many HR workflows. Before adding another policy, start with a practical question: Which tools are helping shape decisions about your people?
What is changing?
Colorado’s Automated Decision-Making Technology law, enacted through SB26-189, replaces the earlier AI framework. Its new requirements begin January 1, 2027. The law addresses covered technology that materially influences consequential decisions, including employment decisions. Coverage depends on how a tool is used—not simply whether a vendor calls it “AI.”
The Colorado Attorney General’s rulemaking is still underway. Proposed rules should not be treated as final requirements. Follow the official rulemaking updates.
1. Inventory the tools touching employment decisions
Review recruiting, applicant screening, compensation, performance, and workforce systems. Record the tool, vendor, internal owner, information used, and the decisions it supports. Include automated features built into software you already use.
2. Map the decision and ask your vendors questions
Identify where a score, ranking, or recommendation affects the outcome and where a person reviews it. Ask vendors for documentation on intended uses, limitations, and human review. Work with counsel to determine which uses are covered.
3. Prepare the people and processes
Plan how your team will handle required notices, requests to correct inaccurate personal data, and requests for human review after adverse decisions. Assign owners and establish a recordkeeping process; the law requires compliance records to be retained for at least three years. Train managers on when to involve HR.
A useful first step this week: Bring HR and your technology owner together to build one shared tool inventory. Use it to identify questions for vendors and legal counsel.
Official sources
Colorado General Assembly: SB26-189 and enacted-law summary
Colorado Attorney General: ADMT rulemaking
Need help organizing your HR technology inventory and preparing your managers? Connect with Nguyen HR Partners.
This update provides general HR information, not legal advice. Review your organization’s specific obligations with legal counsel and check for further legal or rulemaking changes.