Regulation — Colorado state law
Colorado SB 26-189 — educational AI provisions effective Jan 1, 2027
Colorado SB 26-189 replaces SB 24-205 and extends Colorado's high-risk-AI framework specifically to educational decisions. Any institution enrolling Colorado residents or operating admissions-AI whose training data touches Colorado student records is in scope as of January 1, 2027. The lead time between Snapshot and effective date is the window for institutions to establish diligence baselines.
What the statute actually says
"A developer or deployer of a high-risk artificial-intelligence system used in educational decision-making shall use reasonable care to protect consumers from any known or reasonably foreseeable risks of algorithmic discrimination. A rebuttable presumption of reasonable care shall arise where the deployer has (1) completed an annual impact assessment, (2) implemented risk-management program consistent with generally recognized frameworks, and (3) provided consumer notice of the AI system's use."
Representative language, Colorado SB 26-189 — educational AI provisions
"'Educational decision' means a decision, or the material assistance in a decision, that affects a consumer's access to, or the terms of, admission to an educational institution, financial-aid packaging, academic-progression, program-eligibility, or continued enrollment."
Representative definition language, Colorado SB 26-189
What this means in plain English
Colorado's framework works through a rebuttable presumption:
- Reasonable care is the standard. If a consumer is harmed by algorithmic discrimination, the institution's defense is that reasonable care was in place.
- Three elements create presumption. Annual impact assessment + risk-management program + consumer notice.
- Independent evaluation is the strongest way to satisfy the impact-assessment element. Internal-only assessments are legally sufficient but evidentiary-weaker.
What triggers the exposure in the sample
An institution admitting Colorado residents that has not completed a documented impact assessment on its admissions AI as of January 1, 2027 loses the rebuttable presumption. The A3 differential documented in this sample would sit in exactly that gap under Colorado's framework.
What the $499 Snapshot shows against this rule
- Documented impact assessment on one covered AI surface
- Independent-verifier declaration — the strongest impact-assessment evidence
- 3 fix-first items structured as the risk-management program starting draft
- Baseline against which the annual cadence runs
See how Category A/B/C maps to reasonable-care stance →
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Colorado-ready impact assessment on your admissions-AI surface. Get ahead of the January 2027 effective date.
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Snapshot credit applies to Baseline ($2,500) or Enterprise Attestation ($35-55K) upgrade within 30 days.