Does Colorado’s AI law apply to a brand-visibility dashboard?

Not merely because it produces recommendations or scores. Colorado’s SB26-189 replaced the earlier framework with requirements concerning ADMT that materially influences consequential decisions about individuals. The enacted summary identifies areas including employment, education, housing, financial services, insurance, healthcare and essential government services. (leg.colorado.gov)

Our scope assessment is that a dashboard recording whether a software brand appears in category answers is different from a system used to influence an individual’s eligibility for a covered service. That is an analytical distinction, not a legal clearance: assess the actual downstream use, especially if a marketing vendor also sells lead scoring or eligibility tools. (leg.colorado.gov)

The Attorney General released an interim rules draft on 6 October 2026 and scheduled the hearing for 26 October 2026. Customer-facing conversational services also need a separate review under Colorado’s Chatbot Safety Act; the Attorney General identifies 1 January 2027 as its commencement date. (coag.gov)

Important enforcement qualification: the legislature’s final fiscal note, dated 8 September 2026, records an April court restriction on initiating enforcement pending rulemaking and a ruling in X. AI LLC v. Weiser. This research did not independently establish whether a later court order changed that position. Do not present the statutory date as an independently verified enforcement start. (leg.colorado.gov)

What to do now: legal and product owners should document whether the system affects a covered individual decision, review the October draft, and check the court position before advising either that the law is enforceable or that preparations can stop.