AI Impact
Assessment Tool
Colorado SB24-205 requires you to complete a documented impact assessment before deploying any high-risk AI hiring tool — with a $20,000 per-violation penalty and mandatory AG notification if problems are found.
EmployArmor guides you through the assessment, classifies tool risk, generates all required documentation, and tracks your 90-day AG notification window — before you deploy a single line of AI.
What Colorado SB24-205 Requires
This is pre-deployment — not ongoing. You assess before you use the tool, then document and notify if issues arise.
Pre-Deployment Assessment
Colorado SB24-205 requires employers to complete a documented impact assessment before deploying any high-risk AI system used in hiring or employment decisions. You cannot use the tool first and assess later.
Risk Classification
You must classify each AI hiring tool as high-risk or not. Tools that make or substantially influence decisions about hiring, promotion, termination, or compensation are high-risk under Colorado law and require full assessment.
Documentation Requirements
The assessment must document the tool's intended purpose, known limitations, training data, testing methodology, bias mitigation steps taken, and how the tool's output is used in your decision process.
AG Notification
If you discover the AI tool has caused or is likely to have caused discrimination, you must notify the Colorado Attorney General within 90 days of discovery. This is a mandatory reporting obligation, not optional.
Assess every AI hiring tool before the deadline hits
The June 2026 deadline is coming fast. EmployArmor's guided assessment wizard walks you through each required step, classifies your tools, and generates documentation that satisfies Colorado's requirements from day one.
- Guided assessment wizard — step-by-step questions for each tool
- Risk classification engine based on Colorado SB24-205 definitions
- Documentation generator — creates compliant assessment records
- AG notification tracker with 90-day deadline management
- Remediation workflow when issues are discovered
- Assessment archive for all deployed AI hiring tools
AI Impact Assessment Requirements by Jurisdiction
Colorado is first in the US, but the EU AI Act is already in force for multinational employers. California and Illinois are close behind.
| Jurisdiction | Status | Risk |
|---|---|---|
| Colorado | Effective June 30, 2026. Pre-deployment assessment required for high-risk AI. | High |
| California | AB 2930 and related bills would require algorithmic impact assessments. | Medium |
| Illinois | AIVIA in effect. Additional impact assessment requirements pending. | Medium |
| EU (Multinationals) | High-risk AI systems in hiring require conformity assessments. In effect 2025-2026. | High |
Updated March 2026. EmployArmor monitors all 50 states for AI employment legislation.
AI Impact Assessment vs. Bias Audit: What's the Difference?
View AI hiring lawsuits tracker →An AI impact assessment happens before you deploy a tool. Under Colo. Rev. Stat. § 6-1-1701, you analyze the tool's design, limitations, training data, and potential harms — then document your findings before the tool is ever used on a real candidate. The Colorado Attorney General enforces SB24-205 and can request your assessment documentation at any time.
A bias audit (required by NYC Local Law 144) happens after you're using the tool — it's an annual statistical analysis of real outcomes to check for adverse impact. The EEOC enforces 29 U.S.C. § 623 (ADEA) for age discrimination in AI-assisted hiring nationally. Both tools serve different purposes — the AI impact assessment is pre-deployment, the bias audit is ongoing.
EmployArmor manages both. Use the Bias Audit Tool for ongoing annual NYC LL144 compliance, and this AI Impact Assessment Tool for pre-deployment documentation under Colorado law. The DOL OFCCP also monitors AI impact on federal contractors. See our AI hiring compliance checklist for the full picture.
For multinational employers, the EU AI Act requires similar conformity assessments for high-risk AI systems. Our assessment framework covers both Colorado and EU requirements in one workflow.
Frequently Asked Questions: AI Impact Assessment
What is an AI impact assessment and when is it required?
An AI impact assessment is a documented pre-deployment review of an AI hiring tool's purpose, limitations, training data, and potential for harm. Colo. Rev. Stat. § 6-1-1701 (SB24-205) requires this before deploying any high-risk AI system in employment decisions, effective June 30, 2026. You must complete it before the tool touches any real candidates.
What makes an AI hiring tool 'high-risk' under Colorado SB24-205?
A tool is high-risk if it makes or substantially influences decisions about hiring, promotion, termination, or compensation. Automated resume screeners, AI interview analyzers, and ATS ranking engines typically qualify. If in doubt, treat the tool as high-risk and complete the assessment.
What must the AI impact assessment document?
The assessment must cover the tool's intended purpose, known limitations, training data sources, bias testing methodology, mitigation steps taken, and how the output is incorporated into hiring decisions. The Colorado AG can request this documentation at any time under Colo. Rev. Stat. § 6-1-1701.
Is there a notification requirement if the AI causes discrimination?
Yes — mandatory. If you discover the AI has caused or is likely to cause discrimination (including age discrimination under 29 U.S.C. § 623, ADEA), you must notify the Colorado AG within 90 days of discovery. This applies even if the discrimination was unintentional.
How does Colorado's AI impact assessment differ from NYC's bias audit?
Colorado's AI impact assessment (Colo. Rev. Stat. § 6-1-1701) is pre-deployment — completed before any candidate interacts with the tool. NYC's bias audit (NYC Admin. Code § 20-871) is ongoing — required annually while the tool is in use. Both requirements may apply to employers operating in both jurisdictions.
Assess Before You Deploy
Colorado's June 2026 deadline is approaching. Start your impact assessments now so you're covered on day one.