Report and Recommendations
Artificial Intelligence Impact Task Force
February 2025 | Research Publication 832
Legislative Council Staff
Nonpartisan Services for Colorado’s Legislature
Artificial Intelligence Impact Task Force
Members of the Committee
Senator Robert Rodriguez, Chair
Representative Brianna Titone, Vice Chair
Senator Mark Baisley Representative Ron Weinberg
Ruthie Barko David MacLeod
John Bliss Jon Nordmark
Michael Brent Tatiana Rice
Henry Claypool Jeffery Riester
David Edinger Anaya Robinson
Kjersten Forseth Brittany Morris Saunders
Loren Furman Matt Scherer
Grace Gedye Seth Sternberg
Margo Kaminski Eric Swanson
Adeel Khan Luke Swanson
Vivek Krishnamurthy Jeff Swoboda
February | 2025
Table of Contents
Introduction ................................................................................................................................................. 1
Meetings and Topics Discussed................................................................................................................ 1
Recommendations...................................................................................................................................... 3
Issues with Apparent Consensus for Proposed Changes ......................................................... 3
Issues Where Consensus on Changes Appears Achievable with Additional Time and
Stakeholder Engagement ............................................................................................................. 3
Issues Where Achieving Consensus Likely Depends on Whether and How to Implement
Changes to Multiple Interconnected Sections........................................................................... 4
Issues with Firm Disagreement on Approach and Where Creativity Will Be Needed ......... 4
This report is also available online at:
https://leg.colorado.gov/committees/artificial-intelligence-impact-task-force/
2025-regular-session
Introduction
The Artificial Intelligence Impact Task Force (task force) submits this report as a summary of the
task force’s work and recommendations. The task force is charged with considering issues and
proposing recommendations regarding protections for consumers and workers from artificial
intelligence (AI) systems and automated detections systems (ADS).
Over the course of several meetings, the task force engaged in robust discussions on the
information discussed below. All presentations, meeting summaries, handouts, and draft
recommendations from the task force’s meetings are posted on the task force’s 2024 and 2025
websites.
Meetings and Topics Discussed
August 29th, 2024
• Overview of Task Force Charge and Procedures
• Discussion of Future Meetings
September 16, 2024
• Presentation from Professor Margot Kaminski, University of Colorado Boulder, on Legal and
Technical Definitions of AI
• Presentation from Tatiana Rice, Future of Privacy Forum, on Senate Bill 24-205 and U.S. State
AI Legislation
• Presentation from Meghan Pensyl, BSA the Software Alliance, on Perspectives on AI
Regulation
October 21, 2024
• Business and Technology Panel with Presentations from TechNet, Amazon, Salesforce, and
Google
• Public Interest Perspective Panel with Presentations from the American Civil Liberties Union,
Center for Democracy and Technology, and Data Science Institute and Brown University
• Continued Business and Technology Panel with Presentations from Iterate.ai, Soona, Range
Ventures, Ibotta, Microsoft, and IBM
November 13, 2024
• Colorado State Government and AI Panel with Presentations from the Colorado Office of
Information Technology, Office of Economic and International Trade, and Attorney General’s
Office
Artificial Intelligence Impact Task Force 1
December 20, 2024
• Panel of Presentations with the Colorado Technology Association, Colorado Chamber of
Commerce, and TechNet
• Public Interest and Consumer Groups Panel with Presentations from Matt Scherer, Center for
Democracy, and Grace Gedye, Consumer Reports
January 31, 2025
• Committee Discussion on Recommendations
2 Artificial Intelligence Impact Task Force
Recommendations
By holding numerous sessions in which the task force engaged with many stakeholders, the task
force has heard concerns and received proposed revisions on a wide range of provisions in
Senate Bill 24-205. These led to discussions among task force members that identified a number
of potential areas where the law could be clarified, refined, and otherwise improved. Those
discussions revealed that, while there are distinct differences on some issues among
stakeholders, particularly between representatives of industry groups and public interest groups,
there are also many issues on which consensus or mutually acceptable compromise is
achievable.
The task force recommends that discussions among policymakers and stakeholders continue in
the coming weeks and months to achieve consensus and agreement where possible on changes
to the law. It is the task force’s hope that such continued engagement will lead not only to
agreement on issues that appear ripe for consensus and compromise but also on some of the
most contentious issues.
To help frame those future discussions, the remainder of this document groups proposed
revisions into four categories:
• Issues with Apparent Consensus for Proposed Changes;
• Issues Where Consensus on Changes Appears Achievable with Additional Time and
Stakeholder Engagement;
• Issues Where Achieving Consensus Likely Depends on Whether and How to Implement
Changes to Multiple Interconnected Sections; and
• Issues with Firm Disagreement on Approach and Where Creativity Will Be Needed.
We provide examples, where applicable, of the types of proposed changes that fall within each
category.
Issues with Apparent Consensus for Proposed Changes
There are a handful of relatively minor proposed changes presented by stakeholders for which
there appears to be consensus both on the need for revisions as well as the general content of
such revisions. In these instances, the revisions should be incorporated unless other stakeholders
raise strong objections that the task force did not fully consider.
Issues Where Consensus on Changes Appears Achievable with Additional
Time and Stakeholder Engagement
There are also a number of areas where stakeholders have raised concerns and, while there
appears to be consensus that those concerns are valid, there is disagreement on the details of
implementing fixes. In these instances, stakeholders should engage with each other and with
policymakers to craft legislative language that addresses the concern without creating
undesirable spillover effects. Examples include:
• More specifically defining the types of decisions that qualify as “consequential decisions”
under the law to ensure greater clarity for those who may be subject to the law’s
Artificial Intelligence Impact Task Force 3
requirements without excluding applications that significantly impact consumers and
workers.
• Reworking the lists of exemptions to the definition of covered decision systems and from the
obligations that the law imposes on developers and deployers to address both industry and
public interest concerns.
• Proposed changes to the provisions governing the information and documentation that
developers provide deployers.
• Proposed changes to the timing of and triggering events for impact assessments.
Issues Where Achieving Consensus Likely Depends on Whether and How to
Implement Changes to Multiple Interconnected Sections
A somewhat harder set of challenges involves revisions proposed by one group of stakeholders
where there appears to be some consensus that there is room and space to address the
underlying concerns animating the proposals, but where other stakeholders have countervailing
concerns that would need to be addressed to achieve consensus. In these instances, there may
be room for agreement on revisions, but such agreement may require broader compromises
that involve changes to multiple sections of the law. Examples of these proposed changes
include:
• Achieving consensus on proposed changes to the definition of “algorithmic discrimination”
(Section 6-1-1701(1), C.R.S.) may depend on how thornier issues involving
Sections 6-1-1702(1), C.R.S. and Sections 6-1-1703(1) C.R.S., where industry and public
interest groups have strong disagreement on what obligations developers and deployers
should have in preventing algorithmic discrimination and how those obligations are
enforced.
• Proposed changes to the definition of “intentional and substantial modification” may be
rendered irrelevant if consensus can be achieved on fixed intervals for impact assessments.
• Stakeholders’ willingness to accept proposed changes to provisions governing when
companies must provide information to the Attorney General (AG) may depend on whether
other changes are made, including to the law’s direct-to-consumer disclosure and
explanation provisions, and should be considered in consultation with the AG’s office.
• Proposed changes to the requirements of the deployer risk management program might be
considered in tandem with proposed changes to deployers’ impact assessment obligations.
Issues with Firm Disagreement on Approach and Where Creativity Will Be
Needed
The task force identified a number of issues for which stakeholder groups have firm
disagreements about proposed approaches for amendment or even whether amendments
should be made. Because of these disagreements, the task force is unable to make substantive
recommendations with respect to these issues but believes there may be opportunities for
creative solutions for building consensus as stakeholders continue to engage. Examples of these
issues include:
4 Artificial Intelligence Impact Task Force
• The definition of “substantial factor,” which helps define the scope of AI technologies that
will be subject to the law.
• The definition and mechanics of the “duty of care” for developers and deployers, or whether
even to continue to include the concept of a duty of care or to replace it with more or less
stringent obligations.
• Whether to retain, minimize, or expand the small business exemption that currently exempts
deployers with fewer than 50 employees from certain requirements in the law.
• Whether to include any provision that provides an opportunity to cure certain incidents of
non-compliance prior to enforcement by the Attorney General.
• Proposed changes to the law’s trade secret exemptions.
• Proposed revisions to the consumer right to appeal.
• Proposed changes to the scope of Attorney General rule-making and potentially to the
timing of the law’s implementation.
Artificial Intelligence Impact Task Force 5
