AI Governance / Regulation / Metadata

Advocates say Colorado's revised ADMT draft rules let deployers shift blame to developers and data brokers

EPIC, CFA and Fairplay say the October draft drops principal-reason notices, weakens human review and lets deployers cite unknown data sources. They also seek tighter age-assurance data limits under the Chatbot Safety Act.

RegulationUS (Colorado)NotableConsultationOfficial source
15 days: Revised draft's response time for ADMT information requests, replacing 'immediately'

EPIC, the Consumer Federation of America and Fairplay have commented on the Colorado Department of Law’s 6 October 2026 interim draft rules for the Automated Decision-Making Technology Act (SB 26-189) and the Chatbot Safety Act (HB 26-1263). EPIC also testified at a public hearing on 26 October.

According to the groups, the revised ADMT draft removes the duty to give a principal reason for adverse decisions. It gives deployers 15 days, instead of immediately, to answer requests for information. It also drops the rule that reviewers must not be subordinates of the original decision-maker, and adds seven ‘commercial reasonableness’ factors for limiting human review.

The groups say new ‘when known to the Deployer’ wording on data sources excuses gaps in provenance. Deployers without the data could also send consumers to a list of third parties. On chatbots, they back the draft’s data minimisation and call for a ‘strictly necessary’ limit on age-assurance data.

Editor’s note: This article relies solely on comments and a blog post published by the advocacy group EPIC and its co-signatories; the Colorado draft rules themselves were not reviewed.

Why it matters

The draft ties consumer notice, access and correction duties to whether a deployer can name the original and intermediary sources of personal data used by an ADMT, including data brokers. Organisations deploying ADMT for consequential decisions in Colorado should check whether their lineage records and developer contracts can supply those sources, system versions and data categories. Final rules may restore stricter duties if regulators accept the advocates' arguments.

Status: Consultation. Interim draft rules issued 6 October 2026; final rules not yet adopted

Sources

  1. Comments of EPIC, CFA and Fairplay to the Colorado Department of Law on ADMT and Chatbot Safety Act Rulemaking — EPICPrimary source
  2. EPIC, CFA and Fairplay Urge Stronger Rules Under Colorado Automated Decision-Making Technology and Chatbot Laws — EPIC

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