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The Colorado Department of Law filed proposed ADMT and conversational AI service rules and opened a comment period that runs to October 26, 2026
Two comment deadlines matter more than the one on the poster. September 4 buys you a seat in the revised draft; October 5 buys you a mention at the hearing. October 26 mostly buys you a place in the record.
Bottom line: Not binding. These are proposed draft rules filed with the Secretary of State on August 11, 2026, together with a notice of rulemaking hearing and a statement of basis, authority and purpose. They bind nobody unless and until they are finalised. The underlying statutes are already law.
Who this affects: Employment counsel and HR leaders at Colorado deployers of automated decision-making technology, developers whose ADMT materially influences consequential decisions, and operators of consumer-facing chatbots that Colorado teens can reach. Chatbot operators owe the Attorney General an annual report.
Issue date: Rules filed August 11, 2026. Written comments accepted August 11 to October 26, 2026, extended if the hearing continues past that date. Both statutes take effect January 1, 2027.
What changed: Colorado moved from pre-rulemaking to formal rulemaking. The informal comment window closed July 13, 2026; there is now actual draft text on the table, filed as a single instrument covering both SB 26-189 and HB 26-1263.
Analysis: The Department of Law says on its own page that the Chatbot Safety Act does not require rulemaking at all. The Attorney General is doing it anyway, largely because the statute obliges operators to report metrics the Attorney General determines and then, in the Department's words, does not explain what those reports should contain. If you operate a chatbot, the annual report content is the piece being written right now.
Primary sources: Colorado ADMT and Chatbot Safety Rulemaking page · Proposed draft rules (DOCX) · Notice of rulemaking hearing (DOCX)
- Instrument (EN)
- Automated Decision-Making Technology and Conversational Artificial Intelligence Service rules, proposed draft
- Authority
- Colorado Department of Law, Office of the Attorney General
- Jurisdiction
- Colorado, United States
- Status
- Proposed draft, filed with the Secretary of State, formal comment period open
- Bindingness
- None. Draft rules under consultation. The statutes they implement are enacted and take effect January 1, 2027.
- Issue date / next deadline
- Filed August 11, 2026. Comment by September 4 for the revised draft, by October 5 for the hearing, by 11:59 PM MST October 26, 2026 for the record.
- Underlying statutes
- Senate Bill 26-189, signed May 2026, repealing and reenacting the Automated Decision-Making Technology Act provisions of SB 24-205; House Bill 26-1263, the Chatbot Safety Act, signed July 1, 2026.
- Primary source
- https://coag.gov/ai/
The filing and what it covers
On August 11, 2026 the Colorado Department of Law filed proposed draft rules with the Secretary of State, alongside a notice of rulemaking hearing and a statement of basis, authority and purpose. One rulemaking, two statutes. The Department states the purpose plainly: to clarify and implement Senate Bill 26-189 and House Bill 26-1263.
SB 26-189 repeals and reenacts the automated decision-making provisions that arrived in 2024 as Senate Bill 24-205, the law Colorado passed to address algorithmic discrimination in consequential decisions made by high-risk AI. The reenacted version carries new requirements for both developers of ADMT used to materially influence a consequential decision and for deployers who use it, and gives consumers a right to request and correct inaccurate personal data used by ADMT.
HB 26-1263, the Chatbot Safety Act, amends section 17. Per the Department's summary, it requires chatbot operators to estimate the age of users, disclose that the user is interacting with AI rather than a human, safeguard teen users against sexually explicit content and simulated emotional dependence, and provide privacy and account-management tools for minor users. It also requires suicide and self-harm response protocols, and prohibits presenting chatbot output as equivalent to licensed professional services.
Why the Attorney General is writing chatbot rules nobody asked for
The ADMT Act requires rulemaking. The Department must adopt rules clarifying and implementing specific provisions before January 1, 2027. That part is mandatory.
The Chatbot Safety Act does not require rulemaking. The Department says so on the page. The Attorney General nonetheless believes rulemaking would help make compliance obligations clear, and singles out one obligation in particular: the annual report chatbot operators must file with the Office of the Attorney General.
The statutory text the Department quotes requires operators to include any additional metrics necessary to determine the efficacy and reliability of implemented safeguards or detection, removal, and response protocols, as determined by the attorney general. The Department then notes the statute does not provide further explanation or details on the content of these reports. That gap is what the draft rules are filling, and it is the reason a chatbot operator should read this filing even though the Act itself did not call for it.
The deadlines that actually differ
Colorado published three dates, and they are not interchangeable.
Comments in by September 4, 2026 will be considered for a revised proposed draft that the Department has committed to circulate no later than September 23, 2026. Comments in by October 5, 2026 will be considered for any proposed revisions presented at the rulemaking hearing. Comments in by 11:59 PM MST on October 26, 2026 will be considered in drafting the final rules, and if the hearing continues beyond that date, the window runs to the last day of the hearing.
Written comments are posted online at the Department's rulemaking comment site as soon as possible after receipt, and all of them join the official rulemaking record. That is worth knowing before you file something you would rather your competitors not read. The Department strongly encourages early filing precisely so that stakeholders can see each other's positions.
The cost-benefit lever
Under section 24-4-103(2.5), C.R.S., anyone can request a cost-benefit analysis on the proposed rules within five days of their publication in the Colorado Register.
The Department describes two routes: complete the Request a Cost-Benefit Analysis form, or email the Colorado Office of Policy, Research and Regulatory Reform directly.
This is a short fuse and it runs from Register publication, not from the August 11 filing date. If a cost-benefit analysis matters to your position, that is a calendar item, not a comment.
What this does and does not settle
Nothing here changes an obligation today. Both statutes take effect January 1, 2027, and the rules are drafts. A deployer reading this in August 2026 is not out of compliance with anything in the draft.
What it does change is the shape of the target. Until August 11 there was a considerations paper and an informal comment window that closed on July 13. There is now text, and there is a scheduled revision of that text in late September. The distance between the first draft and the final rule is the part you can still move.
The Department's stated reason for all of this is candid enough: it believes it will produce better rules if it receives strong, diverse input. Whether the input arrives from the operators who will carry the reporting burden is a choice those operators are making right now.
What we did not verify
We opened the Colorado Attorney General's rulemaking page at coag.gov/ai and read it in full, including the statutory summaries, the rulemaking history, the comment deadlines and the cost-benefit analysis note.
We did not open the proposed draft rules DOCX, the notice of hearing, the statement of basis, authority and purpose, the pre-rulemaking considerations paper, or the text of SB 26-189 or HB 26-1263 on the General Assembly's site. Every description of what those statutes require is the Department of Law's own summary of them, not our reading of the statutory text.
We make no claim about what the draft rules say. We have not read a line of them. We also do not state a hearing date, because the page we read did not give one; it gives a comment window and refers to a notice of hearing we did not open.
Colorado now has draft text implementing both its automated decision-making statute and its chatbot statute, and the two comment deadlines that shape the outcome fall on September 4 and October 5, well before the headline October 26 close. Chatbot operators have the sharper interest: the Act obliges them to file an annual report whose contents the statute never defines, and this rulemaking is where that definition gets written. Both statutes bite on January 1, 2027, which leaves a short runway once the rules land.
Source File
Open coag.gov/ai and confirm the August 11, 2026 filing of the ADMT and Chatbot Safety Rules with the Secretary of State, the September 4 and October 5 intermediate comment deadlines against the October 26 close, the September 23 date for the revised draft, and the passage stating the Chatbot Safety Act does not require rulemaking.
On August 11, 2026, the DOL filed the Automated Decision-Making Technology & Conversational Artificial Intelligence Service rules with the Secretary of State. The purpose of these proposed draft rules is to clarify and implement Senate Bill 26-189 and House Bill 26-1263. ยท Colorado Department of Law, rulemaking page
FAQ
Do these rules bind anyone now?
No. They are proposed drafts filed for public comment. The Department has committed to circulating a revised draft by September 23, 2026 and will consider comments through October 26. The statutes behind them take effect January 1, 2027.
Is my comment public?
Yes. The Department says written comments will be posted online at its rulemaking comment site as soon as possible after receipt and added to the official rulemaking record.
Why is the Chatbot Safety Act in an ADMT rulemaking?
Because the Attorney General chose to include it. The Department states the Chatbot Safety Act does not require rulemaking, but that rulemaking would help clarify compliance obligations, including the content of the annual report operators must submit to the Office of the Attorney General.
What is the cost-benefit analysis route?
Under section 24-4-103(2.5), C.R.S., anyone can request a cost-benefit analysis within five days of the rules being published in the Colorado Register, either through the Department's request form or by emailing the Office of Policy, Research and Regulatory Reform.
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