If you hire in Colorado and use tools like Workday, HireVue, iCIMS, Lever, or anything with "AI matching" in the sales deck to score, rank, or filter applicants (platform presence alone doesn't prove a specific feature is enabled — that's exactly what the inventory step below is for) — SB 26-189's disclosure duties — and the Attorney General's power to enforce them — took effect the day it was signed, May 14, 2026; the rest of the law lands January 1, 2027. NoticeStack is the plain-English compliance hub plus a ready-to-adapt document pack, so HR can start building a documented paper trail now instead of scrambling for a rushed legal engagement while enforcement is already live.
SB 26-189's disclosure, consumer-rights, and enforcement provisions are already in force — it was signed May 14, 2026 — and its remaining provisions take effect January 1, 2027. This clock runs to that date; the duties themselves are live now.
The Situation
SB 26-189, signed May 14, 2026, replaces the repealed Colorado AI Act. If your counsel briefed you on the old law, that briefing is now shelf paper. The new statute is what governs now — its disclosure and enforcement provisions are already in force, with the remaining provisions effective January 1, 2027.
The duties attach to employers using automated decision tools in hiring — not just to the vendors who build them. Your vendor's compliance page covers their exposure, not yours.
The AG's rules aren't due until January 1, 2027, so details on that piece may still shift — but that's separate from disclosure and enforcement, which are already in force now. The wrong response is to freeze on either front. The right response is documents drafted to the statute now, updated when rules land. That update is included, free.
Enforcement sits with the Colorado Attorney General. For actions before January 1, 2030, the AG must first give a 60-day notice and chance to cure — but only where a cure is deemed possible, and it won't reach every violation. That time-limited, conditional window is not a reason to ignore the law; it's a reason a documented good-faith compliance file is one of the most valuable things HR can put in place this year.
Inside the Pack
Pre-screening notice language for career pages, job posts, and application flows — drafted to the statute's disclosure duties.
Ready-to-adapt disclosure for an applicant when a tool is a substantial factor in an adverse decision — the tool's role, data and human-review rights, sent within 30 days.
Check every tool that might score, rank, or filter humans — common names like Workday, HireVue, iCIMS, Lever, and the plugins nobody remembers buying — so you know what's actually enabled, not just installed.
A dated, sign-off-ready checklist that becomes your good-faith paper trail if the AG ever asks.
The exact questions to send your ATS vendor about how their AI features work — in writing, for the file.
Employee-handbook insert and internal announcement copy so legal, HR, and recruiting say the same thing.
The Colorado AG has not finalized rules under SB 26-189. When rules land and any template needs to change, every buyer gets the revised pack free, with a redline of what changed and why. You are not buying a PDF; you're buying a document set that tracks the statute until the effective date and beyond.
Pricing
Honest scope note: NoticeStack is a document pack and educational resource, not legal advice, and we are not your attorneys. It exists for employers who want solid, statute-tracked paperwork without a heavyweight enterprise subscription. When your situation needs a lawyer, Tier III says so out loud.
Objections, Handled
Because the statute — signed May 14, 2026 — already defines the core duties, its disclosure and enforcement provisions are already in force, and the January 1, 2027 date for the remaining provisions doesn't move while you wait. Every buyer gets a free, redlined update when final rules land. Buying now means your inventory, notices, and paper trail are already drafted to the statute; waiting means starting from zero after enforcement has already had time to act.
If you have counsel on retainer with bandwidth, great — hand them this pack as the starting draft to work from rather than billing the first-draft hours. Enterprise HR-compliance platforms are typically sold as annual subscriptions, and employment-attorney time is billed hourly; NoticeStack is the layer below that — statute-tracked documents for employers whose exposure doesn't justify a larger engagement.
And when it does justify one, we say so — Tier III is a free referral, not an upsell.
Straight answer: enforcement is by the Colorado Attorney General, and that enforcement authority is already in force. For enforcement actions before January 1, 2030, the AG must first give a 60-day notice and opportunity to cure — but only where a cure is deemed possible, so it's a time-limited, conditional window, not a standing guarantee. There is no private right of action bounty-hunting here, and we won't pretend otherwise. The real risks are (1) scrambling to cure with no inventory of your own tools if a cure window even applies, and (2) the reputational and paper-trail exposure of having ignored a hiring-fairness law in writing. A dated compliance file is a low-cost head start against both.
Maybe not — but check before you conclude that. If your ATS ranks, scores, recommends, or auto-rejects candidates — features Workday, HireVue, iCIMS, and Lever can all offer, though platform presence alone doesn't prove any of them is enabled on your account — you're likely in scope. The Vendor Inventory Worksheet in the pack exists precisely to answer this question with evidence instead of a hunch — it walks you tool by tool through what actually scores, ranks, or filters candidates, so your answer is documented rather than assumed.
No. NoticeStack provides template documents and educational material about SB 26-189. It is not legal advice and does not create an attorney-client relationship. For advice on your specific situation, consult a licensed Colorado employment attorney — and if you need one, ask us for the referral list.
If you employ or hire people in Colorado, Colorado's hiring law reaches you regardless of where your HQ sits — the same way NYC's Local Law 144 reached national employers hiring into New York. Multistate employers are, if anything, the buyers who most need a per-state document layer rather than a one-size-fits-all policy.