Colorado AI Act
Colorado (statewide)
Automated decision-making technology (ADMT) in consequential decisions
Full guide
NYC Local Law 144
New York City
Automated hiring and promotion tools (AEDTs)
Full guide
Illinois AIVIRA
Illinois (statewide)
AI analysis of employment video interviews
Full guide
California AB 2013
California (statewide)
Generative AI training data transparency
Full guide
Side-by-side comparison
| Attribute | Colorado AI Act | NYC Local Law 144 | Illinois AIVIRA | California AB 2013 |
|---|---|---|---|---|
| Jurisdiction | Colorado (statewide) | New York City | Illinois (statewide) | California (statewide) |
| Key dates | Applies January 1, 2027 (SB 26-189, signed May 14, 2026) | Effective January 1, 2023; DCWP enforcement since July 5, 2023 | Effective January 1, 2020 | Effective January 1, 2026 |
| Primary focus | ADMT that makes or materially influences consequential decisions | AI hiring and promotion tools (AEDTs) | AI video interview analysis | Generative AI training data transparency |
| Who must comply | Deployers and developers doing business in Colorado whose ADMT affects Colorado consumers | Employers and agencies using AEDTs for jobs located in NYC, including NYC-tied remote roles | Employers using AI to analyze video interviews of Illinois applicants | Developers of generative AI made publicly available to Californians (released or substantially modified since January 1, 2022) |
| Key obligation | Pre-use notice, adverse-decision explanation, human-review right, three-year records | Annual independent bias audit (including intersectional categories), public results, 10-day advance notice | Notice, explanation of the AI, written consent, 30-day deletion on request | Public disclosure of training data sources and characteristics |
| Max penalty | $20,000 per violation | $500 first violation, up to $1,500 per subsequent violation, per day | None specified in the statute | None AI-specific; enforcement expected under California's Unfair Competition Law |
| Private lawsuit? | No | No | Not specified in the statute | No AI-specific right of action |
| Enforcement | Colorado Attorney General (conditional 60-day cure until January 1, 2030) | NYC Dept. of Consumer and Worker Protection | No enforcement mechanism specified | Expected via California's Unfair Competition Law |
| Sector scope | All sectors using covered ADMT (insurer and HIPAA-entity carve-outs apply) | Employment only | Employment (video interviews) only | Generative AI developers |
Which laws reach which teams
HR tech and hiring platforms
If you offer automated resume screening, candidate scoring, or video interview analysis to employers, your customers need annual bias audits for NYC-located jobs and consent and deletion workflows in Illinois.
Generative AI developers
If you train generative models and make them available to California users, AB 2013 requires public training-data disclosure. The EU AI Act adds separate GPAI obligations, in force since August 2, 2025.
Enterprise AI deployers
If your ADMT makes or materially influences decisions in employment, lending, housing, insurance, health care, or education for Colorado consumers, notice and rights duties apply from January 1, 2027.
Financial services
Institutions using AI for credit, underwriting, or hiring face the most overlap: Colorado's ADMT duties, NYC's bias-audit requirement for NYC jobs, and EU high-risk classification for creditworthiness AI.
The patchwork problem
The EU AI Act creates one framework across 27 countries. US AI compliance is a growing set of state and local laws with different triggers, obligations, and enforcers. A single AI product used across the US can be subject to NYC's bias-audit rule, Colorado's notice and rights duties, Illinois's consent and deletion rules, and California's training-data disclosure at the same time.
The practical approach is to build the most demanding requirement into your baseline: a program designed for the Colorado AI Act and NYC LL 144 together, with AB 2013 disclosure documentation, covers most current US obligations and positions you for the states that legislate next.