On October 6, 2026, the Colorado Department of Law released the newest draft of its Automated Decision-Making Technology (ADMT) and Conversational AI Service Rules (the “Revised Draft Rules“). This revised draft builds on the initial draft published on August 11, 2026, and provide updated guidance on the Colorado ADMT Act, previously known as the Colorado AI Act.
The Revised Draft Rules differ in notable ways from the initial draft. Perhaps most importantly, whereas the initial draft solicited input on the threshold issue of the definition of materially influence and de minimis. While the standard chosen is closer to the standard contained in the CCPA’s ADMT regulations, the Revised Draft Rules contain several important differences, including a rebuttable presumption. The Revised Draft Rules make other important changes to the consumer rights rules, including relating to adverse outcome contents, standards for reviewers, and how consumer rights are structured.
The Colorado Attorney General will hold a public hearing on the Revised Draft Rules on October 26, 2026. Organizations subject to the Act should review the latest draft closely ahead of the hearing.
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