Retention is set by the longest clock
California requires at least four years for ADS data; Colorado's incoming act names three. A per-state retention schedule creates a gap the moment a candidate touches two states.
Pending and future
Pending AI hiring laws
Signed but not yet operative, passed but not signed, or still just a bill: three different situations that need three different responses from you. Here is where each one currently stands.
Where each one stands
Reviewed August 26, 2026. Every row was read at the legislature's own page, linked in full below.
| Jurisdiction | Status | What happens next |
|---|---|---|
| Colorado | SB26-189 signed May 14, 2026, repealing and reenacting the 2024 act | Obligations begin January 1, 2027, including deployer notice and three-year record retention |
| Connecticut | SB 5 signed May 27, 2026 as Public Act 26-15 | The employment automated-decision pre-decision notice duty is operative October 1, 2027 |
| New York State | S8706B / A9581B passed the Senate June 4, 2026; not delivered to or signed by the Governor | If enacted, annual reporting to the Department of Labor — not a candidate notice |
| Federal | Executive Order 14365 published December 16, 2025; no preemption statute enacted | State laws described on these pages were in force at the review date |
Colorado — signed, reset once, and due January 1, 2027
Colorado is the clearest illustration of why "enacted" and "enforceable" are different words. The state passed a broad AI act in 2024, postponed it, saw its enforcement stayed during litigation, and then replaced it with a narrower one.
Colorado: jurisdiction and source status
- Jurisdiction
- Colorado (statewide)
- Current law
- SB26-189, Automated Decision-Making Technology — signed May 14, 2026
- Relationship to the 2024 act
- SB26-189 repeals and reenacts the provisions Colorado enacted in SB 24-205, with new requirements for automated decision-making technology in consequential decisions.
- Obligations begin
- January 1, 2027
- Notice duties
- A deployer must give clear and conspicuous notice to consumers at the point of interaction with a covered ADMT, and a plain-language description of the ADMT's role within 30 days after a covered ADMT makes a consequential decision resulting in an adverse outcome.
- Rights
- Request personal data, correct factually incorrect personal data, and request meaningful human review and reconsideration after an adverse consequential decision.
- Record retention
- Developers and deployers must retain records necessary to demonstrate compliance for at least three years.
- Enforcement
- By the Attorney General under the Colorado Consumer Protection Act; a violation is a deceptive trade practice. Before January 1, 2030 the Attorney General must give 60 days notice and an opportunity to cure where a cure is possible. No new private right of action.
- Rulemaking
- The Attorney General must adopt rules clarifying the post-adverse-outcome disclosure requirements by January 1, 2027.
- Last reviewed
- August 26, 2026
- Government source
- Colorado General Assembly SB26-189 · Colorado General Assembly SB24-205
Two details matter if you are planning records rather than following the politics. Colorado's retention period is three years, where California's FEHA rules require at least four, so a single retention schedule has to be set by the longest applicable one rather than per state. And the deployer's disclosure duty is triggered after an adverse outcome, within 30 days, which is a different shape from a pre-use notice and needs a different trigger in a workflow.
Connecticut — signed in 2026, operative for employment in 2027
Connecticut's SB 5 is a wide-ranging act, and the employment piece has the longest clock in it.
Connecticut: jurisdiction and source status
- Jurisdiction
- Connecticut (statewide)
- Law
- SB 5, An Act Concerning Online Safety — Public Act No. 26-15
- Signed
- May 27, 2026
- Employment notice duty
- The act's deployer-to-employee and deployer-to-applicant pre-decision notice duty for automated employment-related decision technology is not operative until October 1, 2027.
- Last reviewed
- August 26, 2026
The gap between signature and operative date is over a year, which is generous by the standards of this area, and long enough that the deadline will arrive after most teams have stopped thinking about it. Whether a specific placement falls inside the act is a question for counsel; the act's own text is linked above.
New York State — passed the Senate, and it is not a notice law
This is the one most likely to be misread, for two reasons: it is New York, and it is about AI in hiring. It is a reporting bill that would stand on its own, rather than an extension of New York City's Local Law 144.
New York State: jurisdiction and source status
- Jurisdiction
- New York State (statewide) — distinct from New York City's Local Law 144
- Bill
- S8706B / A9581B, adding section 201-j to the Labor Law
- What it would require
- Covered businesses would report annually to the Department of Labor on the impact of artificial intelligence on hiring and the nature of their artificial intelligence use. It is a reporting duty, not a candidate notice.
- Status
- Passed the Senate on June 4, 2026 and returned to the Assembly. As of August 26, 2026, the Senate's bill status track showed neither “Delivered To Governor” nor “Signed By Governor” reached.
- Last reviewed
- August 26, 2026
- Government source
- New York State Senate S8706B bill status
A reporting duty and a notice duty are different obligations with different owners. Reporting is an aggregate, annual, employer-level submission. A notice is per-candidate, at a moment in a workflow, and has to be evidenced individually. A team that reads this bill as "New York is adding a notice requirement" will plan for the wrong thing. See also New York State vs New York City.
Federal — a policy framework, not a preemption statute
Federal: jurisdiction and source status
- Jurisdiction
- Federal
- Instrument
- Executive Order 14365, Ensuring a National Policy Framework for Artificial Intelligence
- Federal Register publication
- December 16, 2025
- Status of preemption
- As of August 26, 2026, no federal statute preempting state AI employment laws had been enacted, and the state requirements described elsewhere on these pages were in force.
- Last reviewed
- August 26, 2026
- Government source
- Executive Order 14365, Federal Register
The practical reading is narrow: as of August 26, 2026, the state duties described on these pages applied. Whether federal action changes that for your organization is a question for your counsel.
What is actually plannable here
Most of this is out of an operations team's hands. Three things are in it, and they stay the same however the pending items resolve.
Triggers differ, so the workflow needs more than one
A pre-use notice fires before a tool runs. Colorado's disclosure fires within 30 days after an adverse outcome. New York City's fires ten business days ahead. One trigger will not serve all three.
The evidence question never changes
Whichever rule applies, the later question is the same: for this person, on this date, under which approved version, with what delivery outcome.
How this page is maintained
Every status above is dated and carries the legislature's own page. Statuses in this area change without notice and sometimes reverse — Colorado's did twice. Treat the review date as the extent of what is claimed: this page reports what those sources said on August 26, 2026, not what they say today.
Where a claim could not be verified at a primary source, it is not on this page. That is why the Colorado enforcement history above is described in the terms the General Assembly's own page supports rather than in the terms trade coverage uses.
Common questions
Which AI hiring laws are enacted but not yet enforceable?
As of August 26, 2026: Colorado's SB26-189, signed May 14, 2026, with obligations beginning January 1, 2027; and Connecticut's SB 5, Public Act 26-15, signed May 27, 2026, whose employment automated-decision notice duty is not operative until October 1, 2027.
Did Colorado's original AI Act ever take effect?
Colorado enacted SB 24-205 in 2024. Its implementation was postponed, its enforcement was stayed during litigation, and in 2026 the General Assembly passed SB26-189, which repeals and reenacts those provisions with new requirements. The Colorado General Assembly's page for SB26-189 states the repeal-and-reenact relationship directly.
Does New York State have an AI hiring bill?
S8706B / A9581B would add section 201-j to the Labor Law, requiring covered businesses to report annually to the Department of Labor on the impact of AI on hiring. It passed the Senate on June 4, 2026. As of August 26, 2026 the Senate's own bill status track showed it had not been delivered to or signed by the Governor. It is a reporting bill, not a candidate-notice bill.
Will a federal law override these state AI hiring laws?
No federal statute preempting them had been enacted as of August 26, 2026. Executive Order 14365 set out a national policy framework for artificial intelligence, published in the Federal Register on December 16, 2025. Whether and how it affects a particular state law is a legal question, and the state laws described on these pages were in force.
Should we wait for the picture to settle before building a notice workflow?
That is a business judgment, and your own. What the record shows is that three jurisdictions impose duties today, and the two arriving in 2027 name notice, disclosure and multi-year record retention. Whichever way you decide, the records a notice workflow produces are the same ones every one of those rules asks for.
Three jurisdictions today. Two more with 2027 dates already set.
Notice Tracking keeps approved template versions, candidate references, send timestamps, provider-returned delivery events and export history connected, so adding a jurisdiction is a configuration change rather than a new spreadsheet.
This page is general information about published government requirements, last reviewed August 26, 2026. Requirements change; confirm the current text with the agency and your own counsel before relying on it.