On May 14, 2026, Gov. Jared Polis signed into law the Colorado Automated Decision-Making Technology in Consequential Decisions Act (Colorado AI Act), a simplified AI regulation for developers and deployers of AI that repeals Colorado’s prior comprehensive AI regulation (the 2024 Colorado AI Act) that was set to take effect June 30, 2026, and replaces it with a more targeted framework governing the use of specific automated decision-making technologies (ADMT) to materially influence consequential decisions in certain “covered domains.” The new law takes effect Jan. 1, 2027, by which date the Colorado Attorney General must also adopt rules clarifying the disclosure requirements under the new law.

Link to Click here to read the full GT Alert. Click here to read the full GT Alert.

Tags: AI
Photo of Reena Bajowala Reena Bajowala

Reena R. Bajowala has deep experience in artificial intelligence (AI), cybersecurity, data privacy, and information technology law. With advanced certifications as a Certified Information Privacy Manager (CIPM), a Certified Information Privacy Professional U.S. Private-Sector (CIPP/US), and a Certified Information Privacy Technologist (CIPT), and…

Reena R. Bajowala has deep experience in artificial intelligence (AI), cybersecurity, data privacy, and information technology law. With advanced certifications as a Certified Information Privacy Manager (CIPM), a Certified Information Privacy Professional U.S. Private-Sector (CIPP/US), and a Certified Information Privacy Technologist (CIPT), and being named a Fellow of Information Privacy (FIP) by the International Association of Privacy Professionals, Reena is a trusted advisor to clients navigating complex privacy and cybersecurity challenges. Her leadership extends to her role as Vice Chair of the American Bar Association Business Law Section’s Cyber and Tech Committee and serving on the Steering Committee of the U.S. Secret Service’s Chicago Cyber Fraud Task Force. Reena was previously selected as a 2021-2023 Fellow of the ABA BLS’s Cyberspace Law Subcommittee.

Reena helps companies stand up AI governance programs, including creating policies, procedures, disclosures, vendor management, and trainings for a defensible compliance program. She drafts agreements for companies that are developing and/or deploying AI tools. She keeps up to date on AI legislation and regulatory enforcement domestically and globally. She has helped regulated companies institute programs that navigate complexities of existing privacy regulation and artificial intelligence laws.

When faced with a data breach, including in business email compromise, ransomware, or wire transfer fraud scenarios, clients turn to Reena to investigate, remediate, and comply with legal obligations. She conducts risk assessments, develops privacy and InfoSec compliance programs, and leads proactive incident response planning, including developing incident response and communications plans, and conducting executive tabletop exercises. Reena helps regulated entities comply with cybersecurity requirements.

Reena’s compliance and investigation guidance is informed by her historical wide-ranging litigation and trial experience, including over 100 days of first-chair trial experience. She continues to represent buyers and providers of IT services regarding issues ranging from billing and performance disputes arising from Master Services Agreements and Service Level Agreements to copyright and licensing disputes pursuant to Software Licensing and SaaS agreements in pursuing pre-litigation resolutions, working with the Firm’s experienced litigators as needed to pursue formal claims. Reena also works to protect the interests of companies during software audits.

Reena has been widely recognized for her leadership and pro bono work. She has been named a “cornerstone” of SABA North America, a “best under 40” by NAPABA, and a “powerful and influential woman” by the Illinois Diversity Council. Her dedication to justice has earned her accolades from organizations such as the Shriver Center on Poverty Law and the Public Interest Law Initiative. In 2005, she founded the University of Michigan Law School’s Origins Public Interest Fellowship, which has provided hundreds of thousands of dollars of funding to public interest students.

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Photo of Kieran Dwyer Kieran Dwyer

Kieran Dwyer advises cloud providers and technology companies on technology transactions and partnerships, product development, artificial intelligence (AI), and regulatory compliance. He works with businesses across software, telecommunications, consulting, health care, financial services, and energy industries, working closely with go‑to‑market, product, and partner…

Kieran Dwyer advises cloud providers and technology companies on technology transactions and partnerships, product development, artificial intelligence (AI), and regulatory compliance. He works with businesses across software, telecommunications, consulting, health care, financial services, and energy industries, working closely with go‑to‑market, product, and partner teams. Kieran’s practice covers cloud agreements, strategic partnerships, AI development and deployment, privacy and data protection, competition law, cybersecurity, digital advertising, software and open-source licensing, IT outsourcing, and international expansion. He also engages with regulators on matters involving data use, technology interoperability, and competition, including inquiries by data protection authorities, the FTC, and U.S. congressional and agency staff.

On the commercial side, Kieran structures and negotiates cloud services agreements, channel and resale arrangements, strategic collaborations, and product co‑development engagements. He has experience developing contracting frameworks tailored to regulated industries and partner ecosystems. Kieran has led teams in negotiating multiple strategic deals valued at more than $1 billion, spanning industries such as telecommunications, financial services, automotive, logistics and supply chain, payments, and sports and media. That work includes product development initiatives involving 5G network architectures, intelligent vehicle data platforms, cybersecurity, large‑scale application migrations, and data analytics.

Kieran has been advising clients on AI since 2017. He supports AI and machine learning service launches, including drafting service terms, developing responsible AI policies, and advising on marketing and privacy compliance. In addition to his legal and advisory work, Kieran brings experience as a business executive, having led AI adoption for an organization of more than 6,000 employees. He was responsible for AI productivity and change management initiatives, and working closely with engineering teams on the design and development of AI tools.

Kieran counsels clients on privacy, data protection, and competition compliance with a focus on global sales and marketing activities. He has led in-house privacy teams and designed global privacy compliance programs for GDPR, CCPA, LGPD, and dozens of other data protection regimes around the globe. He has also guided responses to U.S. congressional, FTC, and EU agency inquiries regarding data practices.

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Photo of Elizabeth (Liz) Harding Elizabeth (Liz) Harding

Elizabeth (Liz) Harding helps organizations protect and commercialize of their data assets. Liz is qualified in Colorado and the United Kingdom, and has over 20 years of experience focusing on privacy and data matters, including deep familiarity with the GDPR, CCPA, and various…

Elizabeth (Liz) Harding helps organizations protect and commercialize of their data assets. Liz is qualified in Colorado and the United Kingdom, and has over 20 years of experience focusing on privacy and data matters, including deep familiarity with the GDPR, CCPA, and various other U.S. federal, state, and international privacy and cybersecurity regulations.

Liz applies a risk based approach to privacy compliance, marrying deep technical know-how with industry experience. She supports clients across a wide array of industries including advertising, media and telecommunications, entertainment, financial services, health care, hospitality, retail, education, AI, and cloud based technology.

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Photo of Mikaela Shaw Masoudpour Mikaela Shaw Masoudpour

Mikaela Shaw Masoudpour is a trusted advisor to employers on high-stakes employment matters, combining deep courtroom experience with strategic guidance on workforce management and compliance. She stays on the forefront of the use of artificial intelligence in the workplace, helping clients navigate the…

Mikaela Shaw Masoudpour is a trusted advisor to employers on high-stakes employment matters, combining deep courtroom experience with strategic guidance on workforce management and compliance. She stays on the forefront of the use of artificial intelligence in the workplace, helping clients navigate the evolving patchwork of federal, state, and local AI laws, assessing AI-driven employment tools, and conducting AI bias audits. Executive leadership and boards frequently call on Mikaela to investigate workplace misconduct claims and advise on remediation measures. Mikaela also focuses on pay equity matters, including counselling clients on equal pay and pay transparency laws and conducting proactive audits and compensation analyses.

Mikaela regularly represents clients in courts and before administrative agencies in individual and class claims under Title VII of the Civil Rights Act of 1964, the Family and Medical Leave Act, Americans with Disabilities Act, Age Discrimination in Employment Act, the Fair Labor Standards Act, the Equal Pay Act, the National Labor Relations Act, and other traditional labor and employment statutes.

In addition to handling disputes, Mikaela advises employers on pressing workplace needs from the pre-employment stage through separation of employment, such as litigation- and union-avoidance measures, workforce reductions, personnel policies and procedures, executive employment agreements, independent contractor agreements, severance agreements, leaves and accommodations, restrictive covenants, labor relations and hiring, discipline, and discharge. She also conducts training seminars on a variety of employment topics.

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Photo of Ashton Madigan Ashton Madigan

Ashton Madigan counsels businesses on technology transactions, artificial intelligence governance, and regulatory compliance. She represents companies across multiple industries in negotiating complex technology agreements, including AI partnerships, infrastructure deals, and enterprise software arrangements. Ashton works with clients ranging from startups to Fortune 500

…

Ashton Madigan counsels businesses on technology transactions, artificial intelligence governance, and regulatory compliance. She represents companies across multiple industries in negotiating complex technology agreements, including AI partnerships, infrastructure deals, and enterprise software arrangements. Ashton works with clients ranging from startups to Fortune 500 companies on cross-border transactions and helps organizations navigate the evolving landscape of AI regulation.

Ashton focuses her practice on artificial intelligence contracting and governance. She drafts and negotiates AI terms for both internal technology use and client-facing services across various sectors, including human resources, tax, and marketing. Ashton has negotiated AI partnership agreements between global technology companies and professional services firms. She also develops AI usage policies and guardrails for organizations implementing AI tools. Her work includes advising clients on compliance with the EU AI Act and other emerging AI regulations, helping businesses understand their obligations and develop practical compliance strategies.

In her technology transactions practice, Ashton handles data center agreements, SaaS contracts, and large-scale infrastructure deals. She has negotiated and closed high-value colocation agreements with Fortune 100 clients. Ashton collaborates with technical teams seeking to ensure agreements reflect both business objectives and technical requirements while managing risk across multiple jurisdictions.

Ashton holds certifications as a Certified Information Privacy Professional (CIPP/US) and Artificial Intelligence Governance Professional from the International Association of Privacy Professionals.

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