October 23, 2026

CIPL Response to the Colorado Department of Law on the October 6, 2026 Interim Draft Automated Decision-Making Technology and Conversational Artificial Intelligence Service Rules

On October 23, 2026, CIPL filed a response to the Colorado Department of Law’s October 6, 2026, interim draft rules implementing the Automated Decision-Making Technology in Consequential Decisions Act (the “ADMT Act”) and the Conversational Artificial Intelligence Services Act (the “Chatbot Safety Act”).

ADMT Act: CIPL supports the draft rules’ alignment with Colorado Privacy Act procedures, exclusions for low-risk administrative tools, and the commercial-reasonableness framework for meaningful human review. Our principal recommendations include:

  • Refining “Materially Influence” to distinguish genuine human judgment from automated decision-making.
  • Adding appropriate extensions to the 45-day response framework and clarifying interacting deadlines.
  • Allocating notice obligations according to participants’ actual roles and control.
  • Permitting categorical source disclosures where appropriate, protecting sensitive information, and recognizing equivalent federal disclosures.
  • Providing optional model notices and correcting cross-references.

Chatbot Safety Act: CIPL welcomes the draft rules’ standards-based, privacy-preserving age assurance, proportionate scoping, prohibitions on misleading professional representations, evidence-based crisis detection, and tiered reporting. We recommend:

  • Calibrating age-assurance obligations to service risks, improving access to referenced standards, encouraging the use of privacy-enhancing technologies, and clarifying transitions to adult status.
  • Focusing AI disclosures on demonstrated user understanding rather than rigid timing requirements.
  • Allowing consideration of protective measures and beneficial contexts for engagement-reward features, alongside clearer guidance on emotional-dependence safeguards.
  • Separating public aggregate reporting from confidential technical details that could undermine safety systems if disclosed.

Download Our Response Here

Download Now