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Colorado Repeals and Replaces the Colorado AI Act

By Reena Bajowala, Kieran Dwyer, Elizabeth (Liz) Harding, Mikaela Shaw Masoudpour & Ashton Madigan on May 28, 2026
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Nighttime Downtown Denver Skyline Civic Center Park Colorado

On May 14, 2026, Gov. Jared Polis signed into law the Colorado Automated Decision-Making Technology in Consequential Decisions Act (Colorado AI Act), a simplified AI regulation for developers and deployers of AI that repeals Colorado’s prior comprehensive AI regulation (the 2024 Colorado AI Act) that was set to take effect June 30, 2026, and replaces it with a more targeted framework governing the use of specific automated decision-making technologies (ADMT) to materially influence consequential decisions in certain “covered domains.” The new law takes effect Jan. 1, 2027, by which date the Colorado Attorney General must also adopt rules clarifying the disclosure requirements under the new law.

Click here to read the full GT Alert.

Photo of Reena Bajowala Reena Bajowala

Reena R. Bajowala has deep experience with data security, information technology, and privacy law issues, and litigating class, collective, and plan-wide litigation. She is a Certified Information Privacy Technologist (CIPT), a Certified Information Privacy Professional – US (CIPP/US) and a Certified Information Privacy

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Reena R. Bajowala has deep experience with data security, information technology, and privacy law issues, and litigating class, collective, and plan-wide litigation. She is a Certified Information Privacy Technologist (CIPT), a Certified Information Privacy Professional – US (CIPP/US) and a Certified Information Privacy Manager (CIPM). Through a competitive process, she was selected as a 2021-2023 Fellow of the American Bar Association’s Business Law Section with the Cyberspace Law Subcommittee.

When faced with a data breach, including in business email compromise, ransomware, or wire transfer fraud scenarios, clients turn to Reena to investigate, remediate, and comply with legal obligations. She regularly conducts risk assessments, develops privacy and information security compliance programs, and leads proactive planning for potential data security incidents, including drafting incident response plans, communications plans, and conducting tabletop exercises. In addition, Reena helps evaluate legal risks relating to emerging technologies, including artificial intelligence, connected devices, and drones.

Reena assists Employee Retirement Income Security Act (ERISA) benefit plan sponsors with implementing cybersecurity policies and service provider management programs. The Department of Labor’s current emphasis on cybersecurity allows Reena to utilize her combined decade-plus ERISA and benefit plan counseling and litigation experience and her deep cybersecurity and vendor management practice.

Reena has wide-ranging litigation and trial experience, including over 100 days of first-chair trial experience. She represents buyers and providers of IT services regarding issues ranging from billing and performance disputes arising from Master Services Agreements and Service Level Agreements to copyright and licensing disputes pursuant to Software Licensing and SaaS agreements. Reena also works to protect the interests of companies during software audits.

With a broad-based background in complex dispute resolution, Reena understands the intricacies of class, collective, and plan-wide litigation in the employment and consumer fraud spaces. She has deep experience with lawsuits involving ERISA, having represented plan sponsors and service providers in both benefits and fiduciary matters.

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Photo of Kieran Dwyer Kieran Dwyer

Kieran Dwyer advises cloud providers and technology companies on technology transactions and partnerships, product development, artificial intelligence (AI), and regulatory compliance. He works with businesses across software, telecommunications, consulting, health care, financial services, and energy industries, working closely with go‑to‑market, product, and partner…

Kieran Dwyer advises cloud providers and technology companies on technology transactions and partnerships, product development, artificial intelligence (AI), and regulatory compliance. He works with businesses across software, telecommunications, consulting, health care, financial services, and energy industries, working closely with go‑to‑market, product, and partner teams. Kieran’s practice covers cloud agreements, strategic partnerships, AI development and deployment, privacy and data protection, competition law, cybersecurity, digital advertising, software and open-source licensing, IT outsourcing, and international expansion. He also engages with regulators on matters involving data use, technology interoperability, and competition, including inquiries by data protection authorities, the FTC, and U.S. congressional and agency staff.

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Photo of Elizabeth (Liz) Harding Elizabeth (Liz) Harding

Elizabeth (Liz) Harding helps organizations protect and commercialize of their data assets. Liz is qualified in Colorado and the United Kingdom, and has over 20 years of experience focusing on privacy and data matters, including deep familiarity with the GDPR, CCPA, and various…

Elizabeth (Liz) Harding helps organizations protect and commercialize of their data assets. Liz is qualified in Colorado and the United Kingdom, and has over 20 years of experience focusing on privacy and data matters, including deep familiarity with the GDPR, CCPA, and various other U.S. federal, state, and international privacy and cybersecurity regulations.

Liz applies a risk based approach to privacy compliance, marrying deep technical know-how with industry experience. She supports clients across a wide array of industries including advertising, media and telecommunications, entertainment, financial services, health care, hospitality, retail, education, AI, and cloud based technology.

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Photo of Mikaela Shaw Masoudpour Mikaela Shaw Masoudpour

Mikaela Shaw Masoudpour is a trusted advisor to companies from startups to Fortune 100 in a wide range of employment matters, from strategic employment counseling and internal investigations to proactive audits and compensation analyses to litigation. She provides pragmatic, timely advice to employers…

Mikaela Shaw Masoudpour is a trusted advisor to companies from startups to Fortune 100 in a wide range of employment matters, from strategic employment counseling and internal investigations to proactive audits and compensation analyses to litigation. She provides pragmatic, timely advice to employers for their pressing workplace issues, including hiring, leave and disability, remote work, performance management, pay equity, restrictive covenants, wage and hour, workplace policies, and labor relations.

When litigation does occur, Mikaela regularly represents clients in courts and before administrative agencies in individual and class claims under Title VII of the Civil Rights Act of 1964, the Family and Medical Leave Act, Americans with Disabilities Act, Age Discrimination in Employment Act, the Fair Labor Standards Act, the Equal Pay Act, federal labor laws, and other employment statutes. She leverages her deep courtroom experience to assist employers with litigation prevention and crisis management.

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Photo of Ashton Madigan Ashton Madigan

Ashton Madigan counsels businesses on technology transactions, artificial intelligence governance, and regulatory compliance. She represents companies across multiple industries in negotiating complex technology agreements, including AI partnerships, infrastructure deals, and enterprise software arrangements. Ashton works with clients ranging from startups to Fortune 500

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Ashton Madigan counsels businesses on technology transactions, artificial intelligence governance, and regulatory compliance. She represents companies across multiple industries in negotiating complex technology agreements, including AI partnerships, infrastructure deals, and enterprise software arrangements. Ashton works with clients ranging from startups to Fortune 500 companies on cross-border transactions and helps organizations navigate the evolving landscape of AI regulation.

Ashton focuses her practice on artificial intelligence contracting and governance. She drafts and negotiates AI terms for both internal technology use and client-facing services across various sectors, including human resources, tax, and marketing. Ashton has negotiated AI partnership agreements between global technology companies and professional services firms. She also develops AI usage policies and guardrails for organizations implementing AI tools. Her work includes advising clients on compliance with the EU AI Act and other emerging AI regulations, helping businesses understand their obligations and develop practical compliance strategies.

In her technology transactions practice, Ashton handles data center agreements, SaaS contracts, and large-scale infrastructure deals. She has negotiated and closed high-value colocation agreements with Fortune 100 clients. Ashton collaborates with technical teams seeking to ensure agreements reflect both business objectives and technical requirements while managing risk across multiple jurisdictions.

Ashton holds certifications as a Certified Information Privacy Professional (CIPP/US) and Artificial Intelligence Governance Professional from the International Association of Privacy Professionals.

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  • Posted in:
    Privacy & Data Security
  • Blog:
    Data Privacy Dish
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source
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