Legislative Updates

The most consequential change on the board is at the EU level: under the now-finalized Digital Omnibus, the AI Act’s high-risk obligations have been pushed from August 2, 2026 to December 2, 2027 for standalone systems (and to August 2, 2028 for AI embedded in regulated products), giving employers that use AI in hiring and HR meaningfully more time to prepare. Closer to home, Colorado has repealed and replaced its landmark AI Act (SB 24-205) with SB 26-189, effective January 1, 2027, moving to a lighter, notice-based disclosure model after a federal court blocked enforcement of the original law. California’s AI Transparency Act, meanwhile, became operative on August 2, 2026 — its compliance date now anchored in amending bill AB 853 rather than the original SB 942 — while further amendments, including a “No Robo Bosses” human-review requirement for employment decisions, await the governor’s signature. The practical takeaway: near-term EU pressure has eased, but employers should re-confirm their U.S. state obligations against the correct, current statutes rather than the original bills.