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nortonrosefulbright.com2026-05-20

Colorado enacts revised AI law | United States | Global law firm - Norton Rose Fulbright

PolicyIndustry

Ah, Colorado — the state that brought us the Denver omelette and legalised marijuana is now pioneering a new frontier: regulating artificial intelligence without actually saying 'artificial intelligence.' The Revised CO AI Act (note the 'AI' in the title, a cheeky wink) replaces the term with 'automated decision-making technology' (ADMT), defined as any technology that processes personal data to generate recommendations, rankings, or scores used to make decisions concerning an individual. Because nothing says 'we're tackling the most transformative technology since fire' like a euphemism that sounds like a 1970s Soviet computer terminal.

The revised act is, naturally, an improvement on the original — which presumably used the dreaded 'AI' word and scared the tech lobby into a frenzy. By rebranding the beast as ADMT, Colorado's legislators have performed a neat trick: the definition is broad enough to cover credit scoring, insurance algorithms, and rental decisions, yet narrow enough to sidestep the generative models that actually make people nervous. So the hallucinating chatbot that advises you on legal matters? Safe. The algorithm that decides whether you get a mortgage? Suddenly regulated. It's a masterpiece of targeted impotence.

Still, one has to applaud the sheer audacity of passing any law at all while federal regulators snack on their power lunches. Colorado has become the first state to attempt a blanket regulation of algorithmic decision-making — albeit one that refuses to name the technology it's regulating. It's like legislating against 'automobile transportation' while nodding at the 18-wheeler barrelling down the highway. The revised act goes into effect in 2026, giving companies plenty of time to rename their 'AI systems' as 'ADMT systems' on paper. Problem solved. Pass the popcorn.

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● REC · 2026