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The ADMT & AI Notice Playbook: California and Colorado Automated-Decision Rules for 2027

Our ADMT and AI Notice Playbook walks through California’s CCPA automated decision-making rules and Colorado’s SB 26-189, both starting January 1, 2027, in nine steps, with a scope decision tree, notice and disclosure templates, a vendor questionnaire, a 7-week countdown and a one-page checklist.

Nov 14, 2026 24 min read

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Our ADMT and AI Notice Playbook walks through California’s CCPA automated decision-making rules and Colorado’s SB 26-189, both starting January 1, 2027, in nine steps, with a scope decision tree, notice and disclosure templates, a vendor questionnaire, a 7-week countdown and a one-page checklist. Read all 18 pages below.

Captain ComplianceCompliance Guide · Edition 01
California CCPA ADMT rules + Colorado SB 26-189

The ADMT &
AI Notice
Playbook

How to find, disclose and defend every automated decision your business makes about people, before California and Colorado start enforcing on January 1, 2027.

9 stepsNotice templatesScope decision tree7-week countdown
California
Jan 1, 2027
ADMT pre-use notice, opt-out and access rights for significant decisions
Colorado
Jan 1, 2027
SB 26-189 notice, 30-day adverse-decision disclosure and human review
By Richart Ruddie · Captain ComplianceNovember 2026
Contents

The playbook

—The two laws at a glanceCalifornia and Colorado, side by side03
01Check your scopeA decision tree for both states04
02Inventory every automated decisionWhat counts, what doesn’t, and a template05
03Test the human in the loop“Replace” vs. “materially influence”06
04Write the pre-use noticeRequired contents and a sample07
05Build the opt-out or the appealCalifornia’s choice, and how to run it08
06Answer access requests and adverse decisionsExplanations people are owed, with a template09
07Design human reviewA workflow that holds up10
08Get what you need from vendorsDocumentation and contract terms11
09Keep the evidenceRisk assessments and records12
—Playbooks by sectorHiring, lending, housing, health, education, insurance13
—7-week countdown, checklist, FAQ, sources14
Why this guide

A score is now a decision, and a decision now needs a notice.

On January 1, 2027, two states start regulating the same thing from different angles. California’s CCPA regulations give consumers a right to know about, opt out of, and get an explanation of automated decision-making technology (ADMT) used for significant decisions. Colorado’s SB 26-189 requires notice, a plain-language explanation within 30 days of an adverse decision, a way to correct data, and a chance at human review.

Neither law bans automation. Both require you to say when you use it, explain it when it goes against someone, and put a real person behind it. Most of the work is finding the tools, so we start there.

Richart Ruddie
Founder & CEO, Captain Compliance

The 60-second answer

You probably need this guide if software scores, ranks, screens or recommends outcomes for job applicants, employees, borrowers, tenants, patients, students or policyholders in California or Colorado. You probably don’t if your automation only targets ads, fights fraud, or sorts information for a human who makes the call on their own.

This guide is general information, not legal advice. The templates are starting points to review with counsel.

The ADMT & AI Notice Playbook02
The two laws at a glance

Same start date, different triggers

California asks whether technology replaces human decision-making. Colorado asks whether it materially influences the outcome. Build to whichever is stricter for each step.

TopicCA California CCPA ADMT rulesCO Colorado SB 26-189
Who it coversBusinesses subject to the CCPA that use ADMT for a significant decision about a California consumer, including employees and applicants.Developers and deployers of covered ADMT used for consequential decisions about Colorado consumers, employees and applicants.
TriggerTechnology that processes personal information and replaces, or substantially replaces, human decision-making.Technology whose output materially influences a consequential decision, such as by scoring, ranking or classifying.
Decisions coveredFinancial or lending services, housing, education, employment and compensation, and health care.Same five, plus insurance and essential government services.
Before usePre-use notice with purpose, rights, and how the ADMT works.Clear and conspicuous notice near the point of interaction.
Opt-outYes, unless a human appeal or a narrow hiring or work-allocation exception applies.No opt-out right.
After a decisionAccess right: purpose, logic, result, and how the output was used.Within 30 days of an adverse decision: description, the ADMT’s role, how to get more information, and rights.
Human reviewRequired for the appeal exception; reviewer must be able to change the decision.On request after an adverse outcome, to the extent commercially reasonable, plus a way to correct data.
Assessments and recordsRisk assessment before use; existing processing assessed by Dec 31, 2027; attestation by Apr 1, 2028.Compliance records kept at least 3 years. No impact assessment required.
EnforcementCalPrivacy and the Attorney General. Per-violation fines adjusted for inflation.Attorney General only. 60-day cure period until Jan 1, 2030. No private right of action.

Where they agree

Both exclude advertising. Both protect trade secrets in explanations. Both treat employees and job applicants as covered people. Both start January 1, 2027.

Build once, comply twice

One notice can meet both laws if it includes California’s required contents. One human review process can meet California’s appeal exception and Colorado’s reconsideration right if the reviewer has real authority to change outcomes.

The two laws at a glance03
01
Step 1

Check your scope

Run each automated tool through these questions. If you reach a red box, that tool needs the rest of this playbook.

Does the tool use personal informationto score, rank, screen or decide?YesNoOut of scopeIs the outcome about one of these?Jobs or pay · lending or financial services · housing · educationhealth care · insurance (CO) · essential government services (CO)YesNoOut of scope(ads are excluded)Is the person in California or Colorado?Consumers, employees and job applicants all countCALIFORNIA PATHCOLORADO PATHDoes a qualified human review theoutput and have authority to change it?Must know how to interpret it, analyze it withother information, and be able to decide differentlyIs the output a non-trivial factorthat affects the outcome?Scoring, ranking or classifying counts. Summarizingfor a human, with no score, does not.NoYesYesNoIn scopePre-use notice, opt-outor appeal, access right,risk assessmentLikely not ADMTDocument thehuman review.Check if it’sprofiling.In scopeNotice, 30-day adversedisclosure, correction,human review, 3-yr recordsNot coveredWrite downwhy, andrecheck yearly.

California also checks whether you meet CCPA thresholds. Colorado excludes basic tools like spreadsheets and calculators, general chat tools not set up for these decisions, and uses that are incidental, trivial or clerical.

Step 1 · Scope04
02
Step 2

Inventory every automated decision

Most ADMT isn’t labeled AI. It arrives as a feature inside software HR, lending or property teams already use. Ask each department these questions, then fill one row per tool.

Likely in scope

  • Résumé screeners, assessment scoring and interview-ranking tools
  • Credit, affordability and underwriting models
  • Tenant screening scores and rent-eligibility checks
  • Shift scheduling or task allocation that sets pay or hours
  • Clinical triage, prior-authorization or care-eligibility rules
  • Admissions, scholarship or placement scoring
  • Insurance pricing and claims triage (Colorado)

Usually out of scope

  • Ad targeting and audience building
  • Fraud prevention and security tools
  • Spell-check, spreadsheets and calculators
  • Chatbots that answer questions but don’t decide
  • Tools that only summarize files for a human, with no score
  • Routine scheduling or clerical routing

Watch for drift. A “summary only” tool that adds a fit score or a recommendation next quarter moves into scope.

Inventory template · one row per tool
Tool & vendorDecisionPeopleStatesOutputHuman roleStatus
HireScore
(vendor)
Interview shortlistApplicantsCA, COScore 1–100Recruiter sees score, decidesBoth
RentCheckLease approvalTenantsCOPass / refer / failAuto-decline under 550CO
ShiftPlanHours & payEmployeesCAAssigned shiftsManager can overrideCA
Doc SummarizerClaims intakeCustomersCA, COSummary onlyAdjuster decidesOut

Tool names are illustrative. Add columns for data inputs, vendor contact, notice location and the date you last tested the tool.

Most ADMT doesn’t call itself AI. It calls itself a feature.
Why inventory comes first
Step 2 · Inventory05
03
Step 3

Test the human in the loop

The single most important question in both laws is what your people actually do with the output. A human who rubber-stamps a score doesn’t take a tool out of scope.

California

“Substantially replaces” human decision-making

A tool substantially replaces a human when you use its output to make a decision without human involvement. Human involvement counts only if the person:

  • Knows how to interpret and use the output
  • Reviews and analyzes it with other relevant information
  • Has authority to make or change the decision based on that analysis

Miss any one and the tool is ADMT.

Colorado

“Materially influences” the decision

The output must be a factor that is more than trivial and that affects the outcome, for example by scoring, ranking or classifying people. Human review doesn’t remove a tool from scope here. Instead, it’s one of the remedies you owe after an adverse decision.

Excluded: tools that only summarize or organize information for human review with no score, ranking or recommendation that materially affects the result.

Five questions to ask the people who use each tool

QuestionRed flag answer
How often do you go against the tool?“Almost never.” Ask for override rates by month.
What else do you look at before deciding?“Just the score.” Nothing else is considered.
Can you change the outcome without asking anyone?Overrides need sign-off, or the system won’t allow them.
Were you trained on what the output means?No training records, or training is only on the software’s buttons.
Does anyone review applications the tool rejects?Rejected candidates are never seen by a person.

Practical takeaway

Document the human role for each tool now: who reviews, what they see, their authority, and their override rate. That record is your scope decision in California and your human-review evidence in Colorado.

Step 3 · Human involvement06
04
Step 4

Write the pre-use notice

California must include

01The specific purpose of the ADMT. “To improve our services” is not enough.02The right to opt out and how, or the appeal process or exception that applies instead.03The right to access information about the ADMT, and how to ask.04That you won’t retaliate for using these rights.05How it works: the categories of personal information that affect the output, the type of output, how it’s used, and the alternative process if someone opts out.

Where and when

  • At or before collection of the information the ADMT will use
  • In the channel where you mainly deal with the person (app, portal, email, paper)
  • Before reusing data you collected for something else
  • Readable, accessible, in the languages you normally use

Colorado adds

A clear and conspicuous notice near the point of interaction, such as a link on the application page. A California-compliant notice will usually satisfy it.

Sample notice · hiring
How we use automated tools to review applications

We use [tool name], an automated system, to review applications for [roles]. It looks at the information you give us, such as your work history, skills and answers to screening questions, and gives each application a score from 1 to 100. Our recruiters use that score, along with your application, to decide who moves to an interview.

Your choices. You can ask us not to use this automated review. A recruiter will review your application instead. Opt out of automated application review or email [address].

Want to know more? You can ask how the system was used in your case and what it concluded. Request information about automated review.

We will not treat you differently for using any of these rights. Colorado applicants: if we make a decision that goes against you, we will explain the system’s role within 30 days and tell you how to ask for a person to review it.

If you rely on California’s hiring exception or a human appeal instead of an opt-out, replace “Your choices” with a description of that exception or the appeal process.

Tip

One consolidated notice can cover several tools if it includes the required details for each. Put a short version at the point of use and link to the full notice.

Five mistakes we already see in draft notices
Generic purpose

“To improve our services” fails California’s specific-purpose test.

Buried link

A notice only in the privacy policy isn’t at the point of collection.

Missing output

Say what the tool produces: a score, a rank, a pass or fail.

Banner opt-out

A cookie banner toggle isn’t an acceptable ADMT opt-out.

Stale text

A vendor model update can make the notice wrong. Re-check it.

Step 4 · Pre-use notice07
05
Step 5 · California

Build the opt-out or the appeal

California gives you a choice for each tool: let people opt out, or qualify for an exception. Pick deliberately, because the exception comes with its own obligations.

Option A

Offer an opt-out

Works for any significant decision. You’ll need an alternative process, such as a human reviewer, for everyone who opts out.

Option B

Human appeal exception

Works for any significant decision. Let people appeal to a qualified reviewer who can overturn the result, and let them submit information.

Option C

Hiring or work-allocation exception

Only for admission, acceptance or hiring, or for allocating work and pay. The tool must work for its purpose and not discriminate unlawfully.

If you offer an opt-out

  • At least two methods, one matching how you usually interact with people
  • Online: an interactive form reached from a link in the pre-use notice, titled with what the person is opting out of
  • A cookie banner is not an acceptable method
  • No account required, no verification beyond what’s needed to find the person
  • If they opt out before processing, don’t start. If after, stop within 15 business days and tell your vendors
  • Wait 12 months before asking them to opt back in

If you use the appeal exception

  • Name the reviewer role and train them on what the output means
  • The reviewer must be able to change the decision; otherwise the exception fails
  • Describe the appeal clearly in the notice and in the decision message
  • Let people submit documents or information
  • Answer on the CCPA’s request timelines and keep records

Remember

Exceptions remove the opt-out only. The pre-use notice, access right, non-retaliation rule and risk assessment still apply.

Which option fits?

If your situation is…Usually chooseBecause
High volume, few complaintsB: human appealOnly people who disagree go to a person
Screening job applicantsC, if testing supports it, or BThe hiring exception avoids a parallel manual process
A human already reviews most casesA: opt-outThe alternative process already exists
Step 5 · Opt-out or appeal08
06
Step 6

Explain decisions when people ask

CAAccess requests

When a California consumer asks, explain in plain language:

PurposeThe specific reason you used ADMT for themLogicEnough to understand how it processed their information, which can include key parameters and their specific outputResultThe outcome, how the output was used, and whether it was the only factor or what else countedRightsNon-retaliation and how to use their other CCPA rights

You can withhold trade secrets and security-sensitive details from the logic and result. Verify identity as for other access requests.

COAdverse-decision disclosure

Within 30 calendar days of an adverse consequential decision, send a plain-language disclosure covering the decision, the ADMT’s role, how to get more information about the ADMT and the data used, and the person’s rights. On request, explain how to correct inaccurate data and offer human review and reconsideration to the extent commercially reasonable.

Existing ECOA and FCRA adverse action notices can satisfy overlapping requirements. Watch the Colorado AG’s rules on disclosure content, due by January 1, 2027.

Sample · Colorado adverse-decision disclosure
About our decision on your rental application

On [date], we were not able to approve your application for [property].

How automation was involved. We use [tool], an automated screening system that scores applications using credit history, income and rental history. Your score was below our approval threshold, and it was one of the main factors in this decision, along with [other factors].

Get more information. You can ask us for more detail about the system and the information it used about you: [email / link].

Fix incorrect information. If anything we used is wrong, tell us how to correct it: [instructions].

Ask for a person to review. You can request that a member of our team review and reconsider this decision: [how]. We will respond within [timeframe].

Send within 30 calendar days of the decision. Keep a copy for at least three years.

Write explanations people can use
  • Name the main factors, in everyday words
  • Say whether the output decided the result or was one factor
  • Tell people what they can do next, and by when
  • Skip model jargon like “weights” and “features”

One process, two laws

Route California access requests and Colorado information requests to the same team and template. The facts you need are the same: inputs, output, how it was used, and who decided.

An explanation that only a data scientist can read isn’t an explanation.
Plain language is a legal requirement in both states
Step 6 · Access & adverse decisions09
07
Step 7

Design human review that holds up

One workflow can serve California appeals, California opt-outs and Colorado reconsideration requests. The details below are what regulators and plaintiffs will test.

01Request inForm, email orreply to notice02Pull the fileInputs, output,new info from person03Trained reviewerDoesn’t default tothe system’s answer04DecideUphold or change,with written reasons05Respond & logTell the person,record the outcomeTrack: requests received · time to respond · decisions changed · reasons · reviewer

What makes a reviewer “meaningful”

  • Real authority to override, written into their role
  • Training on what the output means and its known limits
  • Access to the underlying information, not just the score
  • Enough time per case to actually review it
  • Freedom from targets that reward agreeing with the tool

Numbers to watch every quarter

0%override rate is a warning sign, not a success metric
30 daysColorado’s clock for adverse-decision disclosures
15business days to stop processing after a CA opt-out
3 yrsminimum record retention in Colorado
Reviewer training, in one hour

What the tool measures and what it can’t see · its known error patterns · how to weigh new information from the person · when and how to override · how to write the reason down.

If nobody ever overrules the machine, you don’t have a human in the loop.
What both laws are really testing
Step 7 · Human review10
08
Step 8

Get what you need from vendors

You can’t write an honest notice or explanation without knowing how the tool works. Both laws push information from the companies that build ADMT to the companies that use it.

Colorado requires developers to provide
  • Intended uses and known harmful or inappropriate uses
  • Categories of training data
  • Known limitations
  • Instructions for appropriate use and meaningful human review
  • Notice of material updates, with records kept 3 years
California requires ADMT providers to
  • Give business customers the facts they need for their own risk assessments
  • Support opt-outs: service providers and contractors must stop processing within the same 15 business days

In practice you’ll also need the categories of personal information that drive the output to write your notice.

Questions to send every ADMT vendor this month

#QuestionWhy it matters
1Which inputs most affect the output, and what does the output mean?Notice and access contents
2Was the tool tested for accuracy and unlawful discrimination? Can we see results?CA hiring and allocation exceptions
3Can you stop processing a person’s data within 15 business days on request?CA opt-out mechanics
4Can you produce a per-person explanation of a specific result?CA access, CO adverse disclosures
5Do you use our applicants’ or customers’ data to train your models?Risk assessment and notice accuracy
6How will you tell us about material model updates?CO developer duty, re-assessment

Contract note

Colorado makes contract terms that indemnify a party against its own anti-discrimination violations involving covered ADMT void as against public policy, and splits liability between developers and deployers by relative fault. Review indemnities before renewals.

Step 8 · Vendors11
09
Step 9

Keep the evidence

When a regulator calls, the question will be “show me.” Build the binder as you go.

CARisk assessments

Using ADMT for a significant decision, or training ADMT for one, triggers a CCPA risk assessment. It must cover:

  • How the processing works, in operational detail
  • Specific benefits (generic purposes don’t count)
  • Negative impacts on privacy
  • Safeguards you’ll use
  • Who contributed, and approval by someone with authority to stop it
Before use
For any new ADMT use
Dec 31, 2027
For processing already running before 2026
Apr 1, 2028
Attestation and summary to CalPrivacy for 2026–2027 assessments

Keep assessments while processing continues, or 5 years after, whichever is later.

COCompliance records

Developers and deployers keep records showing compliance for at least three years. Colorado dropped the old impact-assessment requirement, but records are what you’ll show the AG to use the 60-day cure period.

The binder, tool by tool

Inventory row and scope decision with reasons
Human-involvement record: roles, training, override rates
Vendor documentation and testing results
Notice versions with dates and where they appeared
Opt-out, access and appeal logs with response times
Colorado adverse-decision disclosures sent
Risk assessment and approver sign-off
Annual review notes and model change history

Set a review rhythm

Quarterly
Override rates, request volumes, response times, notice accuracy.

On every model change
Re-check the notice, the scope decision and the risk assessment.

Yearly
Re-run the inventory and confirm each tool still matches its documentation.

You won’t be asked whether you have a policy. You’ll be asked to show the log.
What enforcement looks like in practice
Step 9 · Evidence12
Playbooks by sector

Where ADMT shows up, industry by industry

The most common tools we see in each sector, and the first move to make.

Hiring & HR

Tools: résumé screeners, video interview scoring, assessments, scheduling that sets hours or pay.

First move: decide whether you’ll rely on California’s hiring exception. If so, get the vendor’s accuracy and bias testing in writing.

Lending & fintech

Tools: credit and affordability models, line-increase engines, collections prioritization.

First move: map your ECOA and FCRA adverse action notices against Colorado’s disclosure, then fill the gaps.

Housing & property

Tools: tenant screening scores, income verification, rent-eligibility rules.

First move: find every auto-decline threshold. Those are the clearest cases of ADMT in both states.

Health care

Tools: triage, prior authorization, eligibility and care-management scoring.

First move: confirm which data is HIPAA-covered and which is CCPA-covered. Patient-facing scheduling and outreach tools often fall under the CCPA.

Education

Tools: admissions scoring, placement tests, scholarship ranking, proctoring flags.

First move: Colorado lets FERPA-compliant processes satisfy overlapping duties. Document which ones you rely on.

Insurance (Colorado)

Tools: pricing and underwriting models, claims triage and fraud-adjacent scoring.

First move: separate true fraud detection (excluded) from claims scoring that affects payouts (covered).

Every sector

Your own workforce counts. HR tools are the most common ADMT we find, and both laws cover employees and job applicants.

Start with the auto-decline. It’s the clearest automated decision you have.
The fastest first win in any sector
Playbooks by sector13
The countdown

Seven weeks to January 1

A realistic plan for a mid-size business starting in mid-November. Assign an owner to each week before you start.

Week 1Inventory
Survey HR, lending, property, health and operations teams. List every tool that scores, ranks, screens or decides. Pull vendor contracts.
Week 2Scope
Run each tool through the decision tree. Interview users about the human role and collect override rates. Record each scope decision.
Week 3Vendors
Send the six vendor questions. Ask for documentation, testing results and opt-out support. Flag indemnity terms.
Week 4Choose your path
For each California tool, choose opt-out, appeal or exception. Draft pre-use notices and the Colorado adverse-decision template.
Week 5Build
Add opt-out links and forms, an access request type for ADMT, and an appeal or reconsideration queue. Connect them to your request tracker.
Week 6Train & review
Train reviewers. Have counsel review notices. Check accessibility and translations. Test the opt-out end to end with vendors.
Week 7Go live
Publish notices by January 1. Start logging requests and disclosures. Open the evidence binder.
2027Then
Watch Colorado AG rules. Complete CCPA risk assessments for older processing by December 31, 2027. Review override rates every quarter.
Legal
Owns
Scope calls, notice text, exceptions, contracts
Business
Owns
Inventory, human review, override data
Privacy ops
Owns
Request handling, logs, evidence binder
January 1 is the start of enforcement, not the end of the project.
Plan for ongoing reviews
The countdown14
One-page checklist

Ready for January 1?

Tick each item only if you can show evidence for it.

Find it
We have an inventory of every tool that scores, ranks, screens or decides about people.
Each tool has a written scope decision for California and Colorado.
We know which tools affect employees and job applicants.
We know which inputs drive each tool’s output.
Tell people
Pre-use notices are live at or before data collection.
Notices state the specific purpose, not a generic one.
Notices explain the type of output and how it’s used.
A Colorado adverse-decision template is ready to send within 30 days.
Give choices
Each California tool has an opt-out, an appeal, or a documented exception.
Opt-outs have two methods and don’t rely on a cookie banner.
Vendors can stop processing within 15 business days.
People can correct inaccurate data and ask for human review.
Explain & review
We can answer an ADMT access request with purpose, logic and result.
Reviewers are trained and have authority to change outcomes.
We track override rates for every in-scope tool.
Appeals and reconsiderations are logged with outcomes and reasons.
Prove it
Vendor documentation and testing results are on file.
Risk assessments are planned, with older processing done by Dec 31, 2027.
Records are kept at least three years (Colorado) and longer where California requires.
Someone owns a quarterly review of tools, notices and metrics.
One-page checklist15
FAQ & glossary

Questions we hear most

Does our customer service chatbot count?

Usually not. It counts only if it makes, or materially influences, a decision about jobs, credit, housing, education, health care, insurance (CO) or government services (CO). Colorado expressly excludes chat tools not set up for these decisions.

Does ad targeting count?

No. Both laws exclude advertising from the decisions they cover. Other privacy rules on sharing and profiling still apply.

A person signs off on every decision. Are we out of scope?

In California, only if that person meets all three human-involvement tests. In Colorado, a human sign-off doesn’t change scope if the tool’s output materially influences the result.

We only operate in one of the two states. Do we need both?

Follow the people, not your offices. Applicants and customers in either state can bring you into scope.

Does this replace our existing adverse action notices?

For lending, Colorado lets ECOA and FCRA adverse action notices satisfy overlapping requirements. Add anything they don’t cover, such as the ADMT’s role and the right to human review.

Do we have to reveal our vendor’s algorithm?

No. Both laws let you withhold trade secrets. You still have to explain, in plain language, what the tool used and how its output affected the decision.

What are the penalties?

California: per-violation fines under the CCPA, set by CalPrivacy or the Attorney General. Colorado: Attorney General enforcement under the Colorado Consumer Protection Act, with a 60-day cure period available until January 1, 2030.

Glossary

ADMT: automated decision-making technology. In California, technology that processes personal information and replaces or substantially replaces human decision-making.
Covered ADMT: Colorado’s term for ADMT used to materially influence a consequential decision.
Significant decision (CA) / consequential decision (CO): a decision about financial or lending services, housing, education, employment or health care. Colorado adds insurance and essential government services.
Human involvement (CA): a person who knows how to interpret the output, reviews it with other information, and can make or change the decision.
Meaningful human review (CO): review by a trained person with override authority who considers relevant evidence and doesn’t default to the system.
Pre-use notice: California’s required notice before ADMT is used on someone’s information.
Adverse outcome: a consequential decision that goes against the person, triggering Colorado’s 30-day disclosure.
Developer / deployer: the company that builds or substantially modifies covered ADMT / the company that uses it to make decisions.
FAQ & glossary16
Sources & notes

Where this comes from

This guide is based on the text of California’s CCPA regulations on automated decision-making technology, risk assessments and cybersecurity audits (approved in 2025 and effective January 1, 2026, with ADMT duties applying from January 1, 2027), and on Colorado SB 26-189 as signed on May 14, 2026, along with law firm analyses listed here.

The templates are illustrative. Adapt them to your tools, your exceptions and your counsel’s advice. Colorado’s Attorney General is writing rules on adverse-decision disclosures and consumer rights, due by January 1, 2027, which may add detail.

Information is current as of November 2026. This guide is for general information and is not legal advice.

Captain Compliance

Captain Compliance helps businesses meet privacy laws without slowing down: consent and GPC, website scanning, privacy request handling, vendor and AI risk, and privacy program management.

Read our companion report: The State of Privacy & AI Governance 2026–2027.

California Code of Regulations, Title 11, Division 6, CCPA regulations: §§ 7001 (definitions), 7150–7157 (risk assessments), 7200–7222 (ADMT pre-use notice, opt-out and access).
Colorado General Assembly, SB 26-189, Automated Decision-Making Technology (signed May 14, 2026; effective January 1, 2027).
Morrison Foerster, “CCPA Regulations on Cybersecurity, Risk Assessments, and ADMT: Across the Finish Line.”
Ogletree Deakins, “Colorado’s New AI Act Targets Automated Decision-Making for Consequential Decisions.”
Finnegan, “Colorado Replaces Landmark AI Act: An Overview of the New SB 26-189 Framework.”
Captain Compliance, The State of Privacy & AI Governance 2026–2027 (November 2026).
Sources & notes17
Next steps

Find your automated
decisions before
regulators do.

Captain Compliance helps you inventory AI and automated tools, publish notices, and handle opt-out, access and appeal requests with a record of every step.

01

Scan & inventory

Find the trackers, tools and vendors touching personal data.

02

Notices that stay current

Privacy notices and disclosures that update as rules change.

03

Requests on deadline

Opt-outs, access requests and appeals, tracked and logged.

Book a demo  →
Or start with a free scan at captaincompliance.com/cookie-scanner
Captain Compliance
© 2026 Captain Compliance
captaincompliance.com
By Richart Ruddie, Founder & CEO
Not legal advice. Current as of November 2026.

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