When Colorado enacted the first comprehensive state AI law in 2024, it imported the conceptual architecture of the EU AI Act: a risk-based regime built on duties of care, risk management programs, and impact assessments. Two years later, and within a matter of weeks, the state has dismantled that legislation. On May 14, 2026, Governor Jared Polis signed Senate Bill 26-189, which repeals SB 24-205 and replaces it with a disclosure-and-rights framework focused on automated decision-making technology (“ADMT”). The new framework takes effect January 1, 2027.

The substance of the rewrite has been well-covered already. Less examined is how Colorado got here, and what the speed and direction of the pivot signal for the rest of the state AI regulatory landscape. The new bill was introduced and signed within two weeks of its introduction. The Governor’s AI Policy Working Group did the heavy lift in advance: roughly six months of stakeholder consultation produced the draft framework released on March 17, 2026. But the final two-week sprint reflects pressure to land the rewrite before the original AI Act’s June 30, 2026 effective date and amid escalating federal headwinds.

Continue Reading Colorado’s AI Reset: Two Weeks, a White House Callout, and a Pivot Away from the EU Model

When the California Privacy Protection Agency (“CalPrivacy”) announced a $1.35 million settlement in September 2025 – the largest CCPA penalty to date – one of the itemized grievances stood out for any practitioner who has wrestled with a vendor redline: the company had failed to amend or enter into third-party data protection vendor contracts by regulatory deadlines.

This hints at where state privacy enforcement is heading. The consumer-facing side of privacy compliance – notices, opt-out links, cookie banners – is visible and testable. But the back-end architecture of a compliant privacy program lives at least in part in vendor contracts, and regulators increasingly treat those contracts as evidence of program maturity (or its absence). Nowhere is this more concrete than in California’s 11 CCR § 7051.

Continue Reading The Paper Trail: State Privacy Law Contracting Requirements