Colorado’s Artificial Intelligence Act (CAIA) has employers asking one big question: Will the state’s groundbreaking AI hiring law really take effect on February 1, 2026? With less than six months to go, lawmakers are heading into a special session on August 21, 2025, to decide whether to delay, refine, or enforce the law as written. For employers using AI in hiring and background checks, the answer could mean the difference between scrambling to meet strict compliance requirements—or gaining valuable extra time to prepare.
The CAIA is the first state law in the U.S. to regulate high-risk AI systems used in employment. Employers who deploy tools like automated resume screeners, candidate assessments, or background scoring platforms will be required to provide consumer notices, appeals, and bias mitigation safeguards. In short, if AI meaningfully influences hiring or promotion decisions, it falls under the law’s scope.
According to HireRight’s 2025 Global Benchmark Report, nearly one-third of North American employers plan to use AI in talent acquisition and workforce management. That means many organizations could soon face compliance obligations—even if their AI programs are still in early pilot stages.
Governor Jared Polis signed the CAIA with hesitation, warning it could create a “complex compliance regime” that stifles innovation. Since then, lawmakers have debated narrowing definitions, exempting small businesses, or extending the timeline. The upcoming special legislative session will reopen that debate.
Some possibilities include:
Delaying implementation until 2027.
Refining definitions of “consequential decisions” to reduce compliance scope.
Phasing in requirements, starting with notices and appeals while postponing audits.
Leaving the law intact and relying on Attorney General rulemaking to clarify details.
What’s unlikely to change: the core consumer protection mandates backed by Senate Majority Leader Robert Rodriguez.
Even amid uncertainty, employers can’t afford to wait. A smart compliance strategy involves:
Identifying high-risk AI systems that directly impact hiring or promotion.
Engaging vendors early, since technical details will be critical for compliance.
Building a phased compliance plan that prioritizes consumer notices and appeal processes.
Designating an AI compliance lead to centralize risk management and documentation.
By preparing now, employers will be ready whether the law takes effect in 2026 or later.
Colorado’s AI hiring law may see adjustments in the special session, but its consumer protection backbone is here to stay. Employers should act as though the February 2026 deadline still stands—while keeping plans flexible in case lawmakers extend or refine the timeline. The safest move? Build transparency, disclosure, and bias-mitigation practices now.
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