Consent and compliance

New hiring laws in Colorado for 2027: the AI law, ID rules and pay changes for recruiters

On this page
  1. Which Colorado hiring laws take effect in 2026 and 2027?
  2. What does SB 26-189 require when AI is used in hiring?
  3. What does HB 26-1283 change at onboarding?
  4. What should staffing agencies change?
  5. Which Colorado changes are proposed but not final?
  6. What did not change?
  7. What changed in the last 90 days?
  8. What to do before January 1, 2027
  9. Questions people ask

As of October 2026, the Colorado change that matters most for hiring in 2027 is SB 26-189. It repealed the 2024 Colorado AI Act and replaced it with a narrower law on automated decision-making technology that applies to hiring decisions made on or after January 1, 2027: notice before a tool materially influences a decision, an explanation within 30 days after a rejection, and correction and human review on request. Since June 3, 2026, HB 26-1283 limits how long an employer may hold a new hire's ID during I-9 verification and requires a written notice. From July 1, 2027, larger employers report EEO-1 data to the state, and Denver's minimum wage rises to $19.84 on January 1.

This page lists enacted laws and adopted rules with confirmed dates, linked to the bill on the General Assembly's site or the agency's page, plus the proposals still open. The standing Colorado hiring checklist is in hiring employees in Colorado, and the AI law is covered in depth in the Colorado AI law for employers.

Not legal advice. This summarizes signed acts, the General Assembly's digest, agency rules and a federal court order as they read in October 2026. Attorney General rules under SB 26-189 were not final; check them before January 2027.

Which Colorado hiring laws take effect in 2026 and 2027?

LawEffective dateWhat changes for hiringSource
2026 PAY CALC Order (7 CCR 1103-14)January 1, 2026Minimum wage $15.16 an hour ($12.14 tipped); executive, administrative and professional exemption at $1,111.23 a week ($57,784 a year)CDLE rules
Denver minimum wage, 2026January 1, 2026$19.29 an hour for work performed in DenverDenver Labor
HB 26-1283, seizure of identification documentsJune 3, 2026Employers may not demand, confiscate or keep an employee's or applicant's government ID, except to complete Form I-9 for no more than ten hours; written notice of the rule at eligibility verificationHB 26-1283
SB 24-205, Colorado AI Act, as delayed by SB 25B-004June 30, 2026, until replacedDeployer duties for high-risk AI in employment on paper; enforcement stayed by agreement in federal court; repealed and replaced from January 1, 2027SB 25B-004
SB 26-189, automated decision-making technologyJanuary 1, 2027, for decisions made on or after that dateNotice before a covered tool materially influences a hiring decision; explanation within 30 days after an adverse outcome; correction and human review on request; records for three yearsSB 26-189
SB 26-052, coal transition hiring preferenceJanuary 1, 2027Businesses building or operating railroads, utilities, energy generation or advanced manufacturing facilities in a coal transition community give qualified coal transition workers a first and preferred opportunity for open jobsSB 26-052
Denver minimum wage, 2027January 1, 2027$19.84 an hour ($16.82 tipped)Denver announcement
HB 26-1207, demographic workforce dataJuly 1, 2027Private employers with 100 or more workers that had to file EEO-1 as of March 1, 2026 must include EEO-1 data, as the form existed on March 1, 2026, in their periodic report to the Secretary of State, even if the federal requirement endsHB 26-1207

What does SB 26-189 require when AI is used in hiring?

SB 26-189 was signed on May 14, 2026 and applies to consequential decisions, including employment decisions, made on or after January 1, 2027. It covers technology that materially influences a decision about a Colorado resident, including a job applicant. A tool a person uses "solely to summarize, organize, translate, draft, route, or present information for human review" is excluded. For an employer using a covered tool, the duties are:

  • Before use: a clear and conspicuous notice that the technology is used.
  • Within 30 days of an adverse outcome, such as a rejection: a plain-language description of the decision and the tool's role, how to ask for more detail including the tool's name, version and developer, and an explanation of the person's rights.
  • On request: a way to correct inaccurate personal data and meaningful human review and reconsideration, to the extent commercially reasonable.
  • Records: kept for at least three years.

The Attorney General enforces the law; it creates no new private right of action. The statute requires rules "on or before January 1, 2027." The Attorney General's AI rulemaking page shows an interim draft on October 6, a regulatory analysis on October 21 and a formal hearing on October 26, 2026, with final rules still to come. Notice wording you can adapt is in the AI disclosure template for candidates.

Why enforcement may start later than January 1

In x.AI LLC v. Weiser, No. 1:26-cv-01515 (D. Colo.), the court's April 27, 2026 minute order granted a stipulation that the Attorney General will not start enforcement, including an investigation, for alleged violations of SB 24-205 or legislation replacing it that occur on or before 14 days after the court rules on xAI's preliminary injunction motion. xAI must file that motion within 28 days after the final rules are adopted. The duties still begin on January 1, 2027; what is paused is the Attorney General's ability to enforce them for that period. Build the notices anyway.

What does HB 26-1283 change at onboarding?

The act took effect when the Governor signed it on June 3, 2026. An employer or its agent may not demand, confiscate, retain or require an employee or applicant, including a migrant or seasonal worker, to surrender a government-issued ID. It may request and temporarily hold one to complete Form I-9, "and in no case for more than ten hours," and may keep a copy. When it verifies employment eligibility, it must notify the person of the rule in writing, in English and in the person's primary language if the employer knows it is not English. A knowing violation is a class 2 misdemeanor. For staffing agencies that run onboarding at a branch or a client site, the practical change is a one-page notice added to the I-9 step and a rule that no one keeps original IDs; I-9 and E-Verify duties themselves are covered in E-Verify in Colorado.

What should staffing agencies change?

  • ID handling: HB 26-1283 applies to "an employer or an employer's agent," so branch onboarding and on-site I-9 events need the ten-hour limit and the written notice in the agency's own process.
  • AI screening for clients: if the agency scores or ranks Colorado candidates with a covered tool, agree with each client in writing who gives the pre-use notice and who answers the 30-day explanation and review requests, because the candidate will not know which company's tool was used.
  • EEO-1 data: an agency with 100 or more workers that files EEO-1 is itself an employer under HB 26-1207 and reports from July 1, 2027.
  • Pay in postings: unchanged, but every posting the agency publishes for a Colorado job still needs the pay range and benefits under the state's posting rules.

Which Colorado changes are proposed but not final?

  • 2027 minimum wage and exempt salary: the Department of Labor and Employment's proposed 2027 PAY CALC Order, "as proposed September 30, 2026; if adopted, effective January 1, 2027," sets $15.71 an hour and an exempt salary of $1,151.23 a week ($59,864 a year). Treat these as the planning numbers for 2027 offers until the final order is posted on the CDLE rules page.
  • Attorney General rules under SB 26-189: drafted and heard on October 26, 2026, not yet adopted.

What did not change?

We found no 2026 or 2027 change taking effect to Colorado's pay transparency and job posting rules, the Job Application Fairness Act's limits on age questions, the ban-the-box law or the non-compete statute; the last non-compete amendment, SB 25-083, took effect August 6, 2025. Those rules are explained in Colorado pay transparency and Colorado non-compete law.

What changed in the last 90 days?

  • August 6: Denver announced the $19.84 minimum wage for 2027.
  • September 30: CDLE proposed the 2027 PAY CALC Order.
  • October 6 to 26: the Attorney General released an interim draft of the SB 26-189 rules, a regulatory analysis, and held the rulemaking hearing.

What to do before January 1, 2027

  1. List every tool that scores, ranks or recommends Colorado applicants, and separate them from tools that only transcribe or summarize for a person who decides.
  2. For covered tools, publish the pre-use notice near the application and prepare the 30-day adverse outcome explanation and the request process for correction and human review.
  3. Ask each vendor for the information SB 26-189 makes developers provide, and check contracts for indemnity clauses the act voids.
  4. Add the HB 26-1283 written notice to the I-9 step and stop keeping original IDs.
  5. Set 2027 pay ranges and exempt salaries against the proposed state figures and Denver's $19.84.
  6. If you file EEO-1, keep collecting voluntary self-identification at onboarding; Colorado will want the data from July 1, 2027.

For the other states with 2027 changes, see new hiring laws for 2027.

Questions people ask

What new Colorado employment laws affect hiring in 2027?

As of October 2026, the main one is SB 26-189, which replaced the 2024 Colorado AI Act with rules on automated decision-making technology that apply to hiring decisions made on or after January 1, 2027. Also new: HB 26-1283, in effect since June 3, 2026, limits holding an applicant's ID to I-9 verification and requires a written notice; HB 26-1207 requires EEO-1 data in Secretary of State reports from July 1, 2027; and Denver's minimum wage rises to $19.84 on January 1, 2027. This is not legal advice.

Is the Colorado AI Act still taking effect?

Not in its 2024 form. SB 26-189, signed May 14, 2026, repealed and replaced SB 24-205 with a narrower law on automated decision-making technology that applies to consequential decisions, including employment, made on or after January 1, 2027. The Attorney General held a rulemaking hearing on October 26, 2026, and under an April 27, 2026 federal court order in x.AI v. Weiser the Attorney General agreed not to start enforcement until after the court rules on a preliminary injunction motion that follows the final rules.

Can a Colorado employer keep a new hire's driver's license during onboarding?

Only briefly. Since June 3, 2026, HB 26-1283 lets an employer hold a government-issued ID only as long as needed to complete Form I-9 and copy it, and never more than ten hours; it may keep a copy. When verifying eligibility, the employer must give the person a written notice of the rule in English and, if known, the person's primary language. Knowingly violating the ban is a class 2 misdemeanor.

What will Colorado's minimum wage and exempt salary be in 2027?

As of October 2026 they are proposed, not final. The Colorado Department of Labor and Employment's proposed 2027 PAY CALC Order, published September 30, 2026, sets $15.71 an hour and an exempt salary of $1,151.23 a week ($59,864 a year), effective January 1, 2027 if adopted. The 2026 figures are $15.16 an hour and $57,784 a year. Denver's 2027 minimum wage of $19.84 is already announced.