In our recent post, AI Regulation on Hold in Colorado—But Employer Risk Isn’t, we flagged that delay did not mean diminished risk. That continues to hold true. Colorado has now approved a comprehensive rewrite of its AI law, while Illinois regulators are advancing practical disclosure requirements for employers using AI in employment decisions.

The direction is clear: AI oversight in the workplace is moving forward—and becoming more operational.

Colorado: Recalibration, Not Retreat

Colorado’s rewrite reflects an effort to make its AI framework more workable—but not less relevant for employers.

Key points:

• Employment uses remain in scope: AI tools used in hiring, promotion, and other employment decisions continue to be treated as “high risk.”
• Governance expectations remain: Employers will still need risk management and oversight frameworks.
• Transparency still matters: Notice and documentation obligations continue, even as details evolve.