Colorado Cybersecurity and AI Laws: Key Privacy Updates for 2026

By Anonymous December 15, 2025
Colorado continues to lead the nation in enacting cutting-edge cybersecurity, privacy, and artificial intelligence legislation. As Q1 2026 approaches, several significant legal developments are shaping how businesses must handle consumer data and AI usage. Below is a summary of key updates to watch.

1. Colorado Privacy Act (CPA) Amendments – Effective July 1, 2025

House Bill 24-1130 and Senate Bill 24-041 introduce new biometric and children's privacy protections. Companies will be required to:
  • Implement written policies for biometric data retention and breach handling
  • Obtain consent before selling or sharing biometric data
  • Conduct Data Protection Impact Assessments (DPIAs) for high-risk services targeting minors
  • Obtain parental consent for targeted advertising or profiling involving children

2. Colorado Artificial Intelligence Act (CAIA) – Effective February 1, 2026

The landmark AI consumer protection bill (SB 24-205) remains unchanged. It mandates that developers and users of 'high-risk' AI systems must:
  • Create AI risk management programs
  • Perform algorithmic impact assessments
  • Notify users when AI impacts decisions
  • Offer human appeals for AI-based decisions

3. Attempted Amendments to CAIA (SB 25-318)

Although SB 25-318 aimed to ease some CAIA requirements, it was voted down. Businesses should continue to prepare for CAIA as originally passed, without expecting regulatory leniency.

4. Colorado AG Opinion Letters & Interpretive Guidance

The Attorney General will issue opinion letters clarifying CPA compliance. Businesses may rely on these for a 'good faith defense' if acting on official guidance. Companies are encouraged to submit requests for interpretive support.