Start here
Find out where you stand before the rules are final.
Book a free 30-minute call, or send a short brief and Mike will reply with a first read on scope.
For Colorado firms that use AI in decisions about people
Your AI already makes decisions about Coloradans. Can you name every one?
Colorado's automated decision-making technology law takes effect January 1, 2027. We find each consequential decision your software touches, list the gaps with an owner for each, and put the notices and review paths in place before that date.
RIG is not a law firm and this is not legal advice. We work alongside your counsel.
In effect
January 1, 2027
SB 26-189, signed May 2026. Source: Colorado Attorney General.
Sec. 1Where the risk sits
The decision you never listed is the one the first question will be about.
It hides in defaults
An applicant screen inside your hiring software, a risk score inside a lending tool, a ranking inside a tenant portal. Many firms switched these on without calling them AI.
Vendor paperwork covers the vendor
Under the law, developers and deployers both carry duties. A vendor statement speaks to their model, not to how your team uses it.
A memo is not a process
Counsel can tell you what the law requires. Someone still has to send the notice, take the correction request and route the human review, every time.
What it costs to wait: rules are still being finalized this fall, and the effective date does not move with them. Every month you wait is a month less to inventory, fix and test before January 1, 2027.
Sec. 2Where the law stands today
A dated record, from official sources.
| Date | What happened | Source |
|---|---|---|
| 2024 | SB 24-205 signed, creating protections against algorithmic discrimination in consequential decisions made by high-risk AI systems. | leg.colorado.gov |
| May 2026 | SB 26-189 signed. It repeals and reenacts those provisions with requirements for automated decision-making technology used in consequential decisions, for both developers and deployers. | coag.gov/ai, leg.colorado.gov |
| August 11, 2026 | The Department of Law filed proposed rules to implement the law. | coag.gov/ai |
| October 2026 | Interim draft rules released October 6; rulemaking hearing held October 26. | coag.gov/ai |
| January 1, 2027 | The law and its provisions take effect. Consumers can request and correct inaccurate personal data used by these systems. | coag.gov/ai |
Read on October 26, 2026. Rules may change before they are final; check the Attorney General's page for the current text.
Sec. 3What you get
Three ways to start. Each one ends with something in writing.
P1 · Readiness call
Talk it through
Thirty minutes with Mike on where AI touches decisions in your firm and whether the law is likely to reach you.
- Your systems, named
- A first read on scope
- Next step in writing
Free
P2 · Inventory and gap list
Know where you stand
Every place AI or automated scoring touches a hire, an application, a price or a denial, and what is missing for each.
- Decision inventory
- Consequential or not, per decision
- Gap list with an owner per gap
Scoped after a short brief
P3 · Audit and controls
Be ready on the date
Everything in P2, plus written assessments per system and the notice, correction and review paths built into the workflow and tested.
- Written assessments
- Controls in the workflow
- A record you can show
Scoped after a short brief
| What is inside | P1 Readiness call | P2 Inventory and gap list | P3 Audit and controls |
|---|---|---|---|
| Conversation about your systems | Yes | Yes | Yes |
| List of every AI-assisted decision, by system and data source | No | Yes | Yes |
| Each decision marked consequential or administrative, with the reason | No | Yes | Yes |
| Vendor settings that moved a system into scope | No | Yes | Yes |
| Gap list with one named owner per gap | No | Yes | Yes |
| Questions for your counsel, ready to send | No | Yes | Yes |
| Written assessment per covered system | No | No | Yes |
| Consumer notice and correction path in the workflow | No | No | Yes |
| Human review path for adverse decisions, tested | No | No | Yes |
| Record of what changed, who approved it and when | No | No | Yes |
Sec. 4By decision
Pick the decision your firm makes. See what we check.
Sec. 5How it works
Scrutineering, before you are on track.
In racing, every car passes inspection before it is allowed out. Same idea here: we check each system before the date, not after the first complaint.
1 · CallFree 30 minutes. You name the systems you know about.
2 · InventoryWe find the ones you did not know about, with your team, in your tools.
3 · Gap listEach gap gets one owner and a plain next step. Your counsel gets the legal questions.
4 · ControlsNotices, correction requests and human review built in and tested before January 1, 2027.
Sec. 6How we work with your data
We look at how decisions are made, not at your customers.
- We map systems and settings. We do not need to copy applicant or customer records to do it.
- Anything we review stays in your systems under your access rules.
- Every finding names the system, the setting and who owns the fix.
- Legal conclusions go to your counsel. We say so in writing on every deliverable.
- You approve each change before it goes into a live workflow.
Sec. 7Who does the work
One accountable person, based in Denver.
Mike Rodgers runs Rodgers Intelligence Group. He does the inventory with your team, in your tools, and signs his name to the gap list.
Where the work turns into building controls, it follows the same approach as our agent governance work. If you want to start smaller, a One-Workflow Review looks at a single process first.
Sec. 8How the ways to prepare compare
Use the right help for each part.
A legal opinion
Best for privileged advice on scope and liability. Check whether it names your actual systems and decisions.
Compliance software
Best for tracking controls and evidence. Check whether it can find a scoring feature switched on inside another vendor's tool.
Your vendor's statement
Best for what their model does. Check whether it says anything about how your team uses it.
An operator-side audit
Best for finding every decision in your own workflow and wiring the notices and reviews in. This is what RIG does, next to your counsel.
Sec. 9Questions
Common questions
Does the law apply to my firm?
It reaches developers and deployers of automated decision-making technology used in consequential decisions, for example in hiring or lending. Whether it reaches you is a legal question for your counsel; the inventory gives them the facts to answer it.
Is this legal advice?
No. RIG is not a law firm. We find and document how decisions are made and build the operating controls. Your counsel advises on the law.
The rules are not final. Should we wait?
The effective date is January 1, 2027. The inventory does not depend on the final rule text, and it is the longest part of the work.
What about the chatbot law?
Colorado also passed a Chatbot Safety Act with the same effective date. If you run a customer-facing chatbot, we flag it in the inventory for your counsel.
Can you keep client data private?
Yes. We review systems and settings inside your access rules. If you need AI that never leaves your firm, see Private AI.
Sources: Colorado Attorney General, Artificial Intelligence; SB 26-189; SB 24-205.