AI Rules for Colorado Law Firms
Last verified July 8, 2026
Colorado has changed its AI framework twice in two years, and firms that built compliance plans around the original Colorado AI Act need to know it never took effect. Clients and carriers in this state are now asking about two separate things: how your firm supervises AI use under the updated rules of professional conduct, and whether any AI-assisted decisions your firm makes about individuals will trigger the disclosure law arriving in 2027.
Where Colorado Stands
Colorado's path has been unusually direct. The original Colorado AI Act (SB24-205) listed legal services among its consequential decisions and would have made some firms deployers of high-risk AI, but it was delayed to June 30, 2026 by SB25B-004 and then repealed and replaced by SB26-189 before it ever took effect. Separately, Rule Change 2026(02) to the Colorado Rules of Professional Conduct took effect January 8, 2026 and speaks directly to how lawyers use AI in practice.
What Your Firm Must Do Now
Rule Change 2026(02) amended the Scope comment and Rule 1.1 comments to state expressly that using AI does not diminish a lawyer's duties, and that competence includes understanding the capabilities, limits, and risks of the AI tools in use. In practice that means your firm should have an AI use policy, train attorneys on it, and verify AI output before it goes to a client or a court. This obligation is already in effect and does not wait for any statute.
What Changes in 2027
SB26-189, signed May 14, 2026, replaces the repealed Colorado AI Act with a disclosure-based framework rather than the earlier risk-tiered model. Beginning January 1, 2027, a firm that uses AI to make or assist a covered decision about an individual, most plausibly in hiring and employment decisions, must give notice of that use and provide a plain-language explanation within 30 days after an adverse decision.
What's Still Pending
Because SB26-189 does not take effect until January 1, 2027, your firm has a window to build the notice and explanation process it requires before the obligation becomes live. The repealed Colorado AI Act (SB24-205) is no longer operative and should not factor into planning going forward.
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