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The Colorado AI Act and Hello Recruiter
Ready for January 1, 2027
Colorado’s AI Act, rewritten by SB 26-189 in May 2026, takes effect January 1, 2027 and covers automated tools that materially influence hiring decisions about Colorado residents. Hello Recruiter gives employers the tool details, human review and records that the Act’s notices and adverse-action process depend on.
At a glance
- Law
- Colorado AI Act, as repealed and replaced by SB 26-189 (signed May 14, 2026)
- Applies to
- Employers doing business in Colorado that use automated decision-making technology to materially influence employment decisions about Colorado residents
- Takes effect
- January 1, 2027. The Attorney General must adopt implementing rules by then.
- Enforced by
- Colorado Attorney General only. No private lawsuits. Penalties up to $20,000 per violation.
- Hello Recruiter status
- Ready for January 1, 2027. Independent bias audit covering Colorado (October 2026).
- Last reviewed
- October 2026
What the law requires
The 2026 rewrite replaced the original 2024 law before it ever took effect. It dropped the old law’s impact assessments, risk management programs, annual reviews and reporting to the Attorney General. For employers, three duties remain:
- Pre-use notice. Before using covered technology, give a clear and conspicuous notice that it materially influences the decision and how to get more information. A notice in the online application is one way to do it.
- Adverse action process. Within 30 days of an adverse decision the technology materially influenced, tell the person what was decided and what role the technology played. Tell them how to get more information, including the tool’s name, version, developer and the types and sources of personal data used, and how to correct their data and ask for human review. On request, let them correct inaccurate data and give them meaningful human review and reconsideration, to the extent commercially reasonable.
- Records. Keep records that show compliance, such as tool version identifiers and changelogs, for at least three years after the decision.
Liability for discrimination is split between the developer (Hello Recruiter) and the employer by relative fault. If an employer uses a tool as the developer intended and documented, the developer answers for discriminatory results; if the employer uses it some other way, the employer does. Contract clauses that shift a party’s own liability for algorithmic discrimination onto the other are void.
How Hello Recruiter helps you comply
| What the law requires | What Hello Recruiter does | What your team does |
|---|---|---|
| Pre-use notice | Discloses AI use to every candidate. You can start from the candidate notice on our NYC page. | Put the notice in your application process. |
| Adverse action notice: the tool’s details | Gives you what the notice needs: tool name (Hello Recruiter Resume Screening System or Hello Recruiter Interviewing System), developer (Hello Recruiter, Inc.), the data used (resume content, application answers and interview transcripts), and the product release in use, from our changelog on docs.hellorecruiter.ai. | Send the notice within 30 days of the decision. |
| Adverse action notice: the tool’s role | Every score traces from evidence to signals to competencies against your criteria, so you can describe the tool’s role in plain language. | Explain how the score fed into your decision. |
| Correcting personal data | Recruiters can re-run the evaluation with a manually entered scorecard and fully override the AI scores, so corrected information changes the outcome. | Handle correction requests and re-evaluate with the corrected data. |
| Human review and reconsideration | The Human Review Center shows reviewers the evidence behind each score. They can enter a scorecard manually and fully override the AI scores. | Offer review by a person with authority to change the decision. |
| Three years of records | Keeps records for US roles 4 years by default and publishes a changelog of product releases on docs.hellorecruiter.ai. | Keep your notices and adverse action records. |
| Use as intended | Documents how the product is meant to be used in our AI Disclosure and product docs, and re-tests for bias whenever the AI model changes. | Use Hello Recruiter as documented, and talk to us before any unusual use. |
| No violation of anti-discrimination law | Independent bias audit covering Colorado’s protected classes; lowest impact ratio 0.985. | Set criteria that are related to the job. |
Common questions
When does the Colorado AI Act take effect?
January 1, 2027. SB 26-189, signed May 14, 2026, replaced the original 2024 law, which never took effect.
Does the Colorado AI Act still require impact assessments?
No. The 2026 rewrite removed impact assessments and risk management programs. Employers give a pre-use notice, run an adverse-action and human-review process, and keep records for three years.
Who is liable if an AI hiring tool discriminates in Colorado, the developer or the employer?
The Act splits liability by relative fault. Using the tool as the developer intended and documented puts the responsibility on the developer; using it another way puts it on the employer.
What tool information goes in an adverse action notice?
The tool’s name, version and developer, and the types, categories and sources of personal data it used. Hello Recruiter supplies these for you.
Does the Colorado AI Act cover candidates who live in other states?
No. It covers decisions about Colorado residents, made by employers that do business in Colorado.
See the audit paperwork
Our bias audit report and security documents are on the trust center.
Other AI hiring laws
- NYC Local Law 144Bias audit, public results and candidate notices
- CaliforniaFEHA automated-decision rules and CCPA ADMT
- IllinoisAI Video Interview Act and HB 3773
- EU AI ActHigh-risk hiring AI, provider and deployer duties
- GDPR and UK GDPRProcessor terms, transfers and human review
- All trust and complianceSecurity, privacy and AI hiring status in one place
This page explains how Hello Recruiter supports compliance. It is not legal advice. Your obligations depend on where you hire and how you use Hello Recruiter, so confirm them with your counsel. If this page differs from our legal documents, the documents govern.
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