Skip to main content Scroll Top

A Software Company in Denver Writing the Packet Colorado Now Asks For

Updated November 2026 · Written and maintained by the Progression Agency strategy team

A customer’s compliance lead writes on December 31 asking for your tool’s intended uses and known limitations, and the question has a legal deadline behind it from the next morning. A software company in Denver that builds anything used in a consequential decision now owes that customer a documentation packet under Colorado’s S.B. 26-189, effective January 1, 2027. This page lists the packet as a table of contents, one line per item, then what the work costs. Progression is based in New York, works with Front Range product teams remotely, and offers on-site sessions on request.

On this page · 11 sections
  1. A question on December 31
  2. What a software company in Denver owes its customers now
  3. The packet, as a table of contents
  4. What writing the packet costs
  5. Is your product covered?
  6. What your customer has to show the consumer
  7. Rights that reach back into your schema
  8. Three years of records
  9. What the Attorney General can do
  10. A brief for your general counsel
  11. Related services and guides

Software that never guides a decision? A LoDo retailer whose software never touches a decision about a person can skip the packet entirely; for the ordinary build, our custom software development page is the better read.

The act is described here as the Colorado General Assembly summarizes it as enacted. Section numbers, definitions, exemptions and any Attorney General rules should be checked against the signed act and with the Attorney General’s office by your counsel, and nothing on this page says that any product or company complies. This page is not legal advice. The email and the packet lines are hypothetical, and no company named here is a Progression client.

A question on December 31

The email arrives late in the afternoon of the last day of the year. A bank’s vendor team uses your scoring tool, and its compliance lead wants to know what the tool is for and where it falls short. The company’s own year end is the least of the pressure: a Colorado law starts the next morning.

A drawn email from a customer's compliance lead sent December 31 at 4:52 p.m. with the subject documentation for your scoring tool, asking for intended uses and known limitations, and a Reply button.A drawn email from a customer's compliance lead sent December 31 at 4:52 p.m. with the subject documentation for your scoring tool, asking for intended uses and known limitations, and a Reply button.
Illustrative example. The reply either has a packet to attach or it does not.

The email above is hypothetical, and it is the question this page is built to answer. A reply that opens with an attachment is a better reply than one that opens with a promise. The sections below build that attachment, one line at a time.

  • Know which customers use your tool in a decision about a person.
  • Write the packet before the email arrives, not after.
  • Keep a dated copy, since the records duty covers what you gave and when.

What a software company in Denver owes its customers now

In 2024, Colorado enacted Senate Bill 24-205 on consumer protections in interactions with artificial intelligence systems. S.B. 26-189, signed in May 2026, repeals and reenacts those provisions with new requirements for automated decision-making technology in consequential decisions.

For a developer, the heart of it is a duty to the customer. Starting January 1, 2027, a developer of technology used to materially influence a consequential decision has to give the deployer technical documentation describing the technology’s intended uses, categories of training data, known limitations, and instructions for appropriate use and human review. Developers also have to notify deployers of material updates or modifications.

The Front Range has plenty of teams in this position. Metro Denver Economic Development Corporation reports a workforce of nearly 116,300 people in the region’s IT-software cluster in 2024, which means a large number of products that may sit inside a customer’s decision process. Ask counsel whether yours does.

What replaced the 2024 law?

The new act replaces it. According to the General Assembly’s summary, S.B. 26-189 repeals and reenacts the 2024 provisions, so the S.B. 24-205 text is no longer the one to follow. Read the signed act and ask counsel what changed for your product.

Who owes what under the act, in plain words
PartyDutyStarts
DeveloperTechnical documentation for the deployer; notice of material updatesJanuary 1, 2027
DeployerClear and conspicuous notice at the point of interaction; a plain language description after an adverse outcomePer the act and the Attorney General’s rules
Developer and deployerRecords that show compliance, kept at least three yearsPer the act
ConsumerMay request data, correction, and human review and reconsiderationPer the act
Attorney GeneralEnforces through the Colorado Consumer Protection ActPer the act
Timeline of the act: signed in May 2026, developer documentation and update notices from January 1, 2027, Attorney General rules due by January 1, 2027, a plain language description within 30 days of an adverse outcome, and a 60 day notice to cure before an action when started before January 1, 2030.Timeline of the act: signed in May 2026, developer documentation and update notices from January 1, 2027, Attorney General rules due by January 1, 2027, a plain language description within 30 days of an adverse outcome, and a 60 day notice to cure before an action when started before January 1, 2030.
Dates as set by the enacted act.

The packet, as a table of contents

Think of the documentation as a short book with a fixed list of chapters. The act names what the technical documentation must describe, and the rest of the list below is how a team keeps it true after launch. Each line says what goes in and who should write it.

  1. Intended uses: what the tool is built to do, for which decisions, and for whom. Written by the product lead.
  2. Categories of training data: the kinds of personal data the tool learned from or uses. Written by the data lead.
  3. Known limitations: where the tool performs poorly or has not been tested. Written by the engineers.
  4. Instructions for appropriate use: how a deployer should and should not apply the output. Written by product and support.
  5. Instructions for human review: how a person checks and can override the output. Written by the product lead.
  6. Update notice log: each material update or modification and the date the deployers were told. Owned by release management.
  7. Retention plan: what is kept, where, for how long and by whom, so records last at least three years. Owned by the records owner.
  8. What the work costs: see the price section below. Written once the other seven lines have a scope.

Item 2: categories of training data

List categories, not rows. A deployer needs to know whether the tool used employment history, payment history or location signals, and does not need a dump of the data set. Write each category in a sentence a customer’s compliance team can read, and say whether the data came from the customer, from the consumer or from a third party.

  • Name each category of personal data the tool uses.
  • Say where each category comes from.
  • Note any category added or dropped after the last version.
  • Keep the list in version control next to the model.

Item 3: known limitations, in writing

A limitation that only lives in an engineer’s memory cannot go to a customer. Keep a running list with the date each item was found, the test that showed it, and what a deployer should do about it. Include places the tool has not been tested as well as places it tested poorly.

The list should be honest and specific. A line such as “performance has not been measured on applicants over 70” is more useful to a deployer than a general caution, because the deployer can route those cases to a person.

Who writes each packet line, and the proof that stays behind
Packet lineWriterEvidence kept
Intended usesProduct leadProduct brief with a date
Training data categoriesData leadData inventory in version control
Known limitationsEngineeringTest reports with dates
Use instructionsProduct and supportCustomer guide, versioned
Human review instructionsProduct leadReview workflow document
Update noticesRelease managementLog of notices and recipients
Retention planRecords ownerPolicy and a retention schedule
1: Intended uses. Written by the product lead, in the words a customer's compliance team would use.
2: Training data. Written by the data or ML lead, listing categories and not rows.
3: Known limits. Written by the engineers who test the system, with dated findings.
4: Use instructions. Written by support and product, so a deployer can follow them.
5: Human review. Written by the product lead with the deployer's reviewers in mind.
6: Update notices. Owned by release management, one entry for each material change.

The six cards above are the lines most teams write first. The last two, the notice log and the retention plan, are the ones that keep working after launch.

What writing the packet costs

The documentation is the smaller part of the bill. The larger part is the engineering that lets a team answer honestly: logs that record what the tool did, a way to hand a case to a person, and a data model that can find one consumer’s record. Progression quotes after a written scope.

Published bands for the builds behind a packet

The bands run from the typical low to the published high for each kind of build.

These are published US price bands (market figures, not a Progression rate card).
What is quotedPublished US bandFits
Internal tool or integration$30,000 to $100,000A review queue, a logging layer or a records tool
Portal or platform$75,000 to $400,000A customer portal with notices, requests and review
SaaS MVP$30,000 to $150,000A first version of a product that guides a decision
US agency or contract rate$100 to $200 an hourDrafting, review and audit work billed by the hour

Hosting, licenses and security testing are on top of these. Our software development company page explains how a scope is written, and app development agency covers the app side. We publish no Denver price and no price for a packet.

Is your product covered?

The summary defines automated decision-making technology as technology that processes personal data and uses computation to generate output, including predictions, recommendations, classifications, rankings, scores or other information, that is used to make, guide or assist a decision, judgment or determination concerning an individual.

A consequential decision is one that relates to an individual’s access to, eligibility for, or compensation related to education, employment, housing, financial or lending services, insurance, health-care services, or essential government services and public benefits. The developer duty reaches technology used to materially influence one of those decisions.

Hypothetical products against the definition
Hypothetical productOutputDecision it may touchQuestion for counsel
Resume ranking toolA ranked list of applicantsEmploymentDoes the ranking materially influence who is interviewed?
Claims triage scoreA score on each claimInsuranceIs the score the basis for denial or only a queue order?
Tenant screening reportA recommendation to approve or declineHousingWho is the developer and who is the deployer?
Retail loyalty couponsA discount offerNone of the listed areasDoes any listed area apply at all?

What if a person makes the final call?

The definition speaks of output that is used to make, guide or assist a decision. A human sign-off may not take the tool outside it. Whether a given arrangement counts as materially influencing a decision is a question for counsel, and the answer belongs in your file.

The summary also says specified entities are exempted from the requirements to the extent they comply with other legal obligations. Do not guess at an exemption. Ask counsel to name the one that applies and the obligation behind it.

Which decision does your product touch?Send us the decision your product touches. You get a free proposal from a software company in Denver with the packet outlined.

Get a free proposal

What your customer has to show the consumer

A deployer has to give consumers clear and conspicuous notice at the point of interaction with a covered technology. After the technology makes a consequential decision with an adverse outcome, the deployer has to give a plain language description of the technology’s role within 30 days. The Attorney General must adopt rules clarifying these post-adverse disclosures by January 1, 2027.

That sentence tells you why the deployer will lean on you. To write a description of the technology’s role, the deployer needs to know what the tool looked at and how its output was used. The packet is the source, and a deployer with no packet has nothing to draw from.

  • Draft a short role description a deployer can adapt for each decision type.
  • Keep the description in plain language, since the act asks for it.
  • Watch the Attorney General’s rules, which are due by January 1, 2027, and update the description when they appear.
  • Give deployers the notice wording their product screens can show at the point of interaction.
Flow of six steps: the developer documents the tool for the deployer, the deployer gives notice at the point of interaction, a decision is made, a description follows an adverse outcome within 30 days, the consumer may ask for data, correction and human review, and both parties keep records for three years.Flow of six steps: the developer documents the tool for the deployer, the deployer gives notice at the point of interaction, a decision is made, a description follows an adverse outcome within 30 days, the consumer may ask for data, correction and human review, and both parties keep records for three years.
A summary for orientation; the signed act and counsel control.

Rights that reach back into your schema

Consumers have the right to request their personal data, to request correction of factually incorrect personal data used by a covered technology, and to request meaningful human review and reconsideration following an adverse outcome.

Each of those rights is a data question before it is a legal one. Can the system find every record about one person? Can a corrected value flow through to the next decision? Can a reviewer see what the tool saw and change the result? A team that cannot answer yes will find the packet hard to keep honest.

Can the system answer a request for one person’s data?

It can if every table that feeds the tool carries a stable person key, and if the tool keeps the inputs it used for each decision. Add the key now. Retrofitting identifiers after a request arrives is slow and error prone.

What does a correction change?

The factually incorrect value should be fixed at its source, and the fix should be visible to every later run. Log the correction with the date, who made it and which decisions used the old value.

  • Add a person key to every table the tool reads.
  • Store the inputs and output of each decision for later review.
  • Build a review queue where a person can see inputs and override outputs.
  • Record each override and the reason.

Three years of records

Developers and deployers both have to retain records necessary to demonstrate compliance with the act for at least three years. The act does not tell a team what format to use, so the design is yours, and the design decides whether a request in year three is a ten minute lookup or a month of digging.

Keep what you gave and when you gave it: each version of the documentation, each update notice and the list of deployers who received them. Keep the evidence behind each limitation. Keep the internal decisions about what counts as a material update. Ask counsel what else belongs on the list for your product.

A record log for the packet
RecordWhy it mattersKeep for
Each version of the documentationShows what a deployer was toldAt least three years
Update notices and recipientsShows deployers were told of material changesAt least three years
Test reports behind each limitationShows the limitation was real and datedAt least three years
Review and override logsShows how human review workedAt least three years
Requests and responsesShows how data and correction requests were handledAt least three years

How should the log be built?

Append only, dated, with the name or role of the person who made each entry. Store it away from the production database, with its own backup, so a rollback does not erase it. Our software teams build audit logging into custom systems as a normal part of the scope.

What the Attorney General can do

The Attorney General enforces the act through the Colorado Consumer Protection Act, and a violation is deemed a deceptive trade practice. Before January 1, 2030, the Attorney General must give a developer or deployer 60 days’ notice and a chance to cure, if a cure is possible.

The act creates no new private right of action. It does set how fault is allocated between developers and deployers in civil actions alleging unlawful discrimination under existing law, which is one more reason for each side to hold clear documents about who did what. Ask counsel how that allocation applies to your contracts.

Does a cure period mean waiting?

No. A cure period is a chance to fix a problem after a notice, and it is only offered when a cure is possible and for actions started before 2030. Teams that already have the packet and the records are the ones best placed to use it.

  • Keep the current packet and every earlier version.
  • Keep the update notices with their recipients.
  • Keep the test reports behind each stated limitation.
  • Keep a named contact who can answer a notice from the Attorney General.

A brief for your general counsel

Copy this card into a document and fill it in before the first call. A team that arrives with it can get coverage and exemption questions answered in one sitting, and can scope the packet and the supporting build from a written list.

Which: Decisions. Every decision your product touches, with the people it concerns.
Who: Deployers. The customers who put the product in front of consumers.
Data: Data categories. The categories of personal data the product uses, written plainly.
Limits: Known limits. The list engineering keeps, with dates and the test behind each.
Keep: Records owner. The person who answers for three years of records.
Ask: Open questions. The coverage and exemption questions your counsel has to answer.

Send the filled card with a link to your product. Our software development company page describes the builds that follow from it, and app development agency covers apps. If your Denver business also wants search help, SEO in Denver has its own page.

Pages that sit beside this packet:

Get a free proposal

Send us the decision your product touches. You get a free proposal from a software company in Denver with the packet outlined.

Get a free proposal

Software and app development

Frequently asked questions

What does a software company in Denver owe under S.B. 26-189?
Technical documentation for the deployers of its product, starting January 1, 2027, if the product is used to materially influence a consequential decision.
When does the act start?
Developer documentation duties begin January 1, 2027, and the Attorney General’s rules on post-adverse outcome disclosure are due by that date.
What replaced the 2024 Colorado AI law?
S.B. 26-189 repeals and reenacts the provisions of S.B. 24-205 with new requirements for automated decision-making technology in consequential decisions.
Who is a deployer?
The business that uses the covered technology in front of consumers. A bank using your scoring tool is the deployer, and you are the developer.
What goes in the documentation?
Intended uses, categories of training data, known limitations, and instructions for appropriate use and human review, plus notice to deployers of material updates.
Do I have to keep records?
Yes. Developers and deployers must keep records necessary to demonstrate compliance for at least three years.
What is the deployer’s notice duty?
Clear and conspicuous notice to consumers at the point of interaction, and a plain language description of the technology’s role within 30 days after an adverse consequential decision.
Can a consumer ask for a person to look at the result?
Yes. After an adverse outcome a consumer may request meaningful human review and reconsideration, and may also request personal data and correction of factually incorrect data.
Which office enforces S.B. 26-189?
The Attorney General, through the Colorado Consumer Protection Act. The act creates no new private right of action.
What does writing the packet cost?
The writing is the smaller cost. Published US bands run from $30,000 to $100,000 for an internal tool or integration, and Progression quotes after a written scope.
Do you have people in Denver?
No. Progression is based in New York, works with Denver teams remotely and can come on site on request.
What counts as a consequential decision?
A decision about access to, eligibility for, or compensation related to education, employment, housing, financial or lending services, insurance, health-care services, or essential government services and public benefits.
What is automated decision-making technology?
Technology that processes personal data and uses computation to generate output used to make, guide or assist a decision concerning an individual.
Does a human sign-off take my tool outside the act?
Not automatically. The definition reaches output used to guide or assist a decision, so ask counsel before relying on a sign-off.
What must a developer do when the product changes?
Notify deployers of material updates or modifications. Keep a log of each notice with the date and the recipients.
When does the 30 day clock start?
After a covered technology makes a consequential decision that results in an adverse outcome for the consumer.
Is there a grace period before an enforcement action?
For actions started before January 1, 2030, the Attorney General must give a 60 day notice and a chance to cure, if a cure is possible.
Does the act let consumers sue?
It creates no new private right of action, though it sets how fault is allocated between developers and deployers in civil discrimination actions under existing law.
Are any companies exempt?
The summary says specified entities are exempt to the extent they comply with other legal obligations. Ask counsel which exemption, if any, fits.
Which documents help scope a packet?
The decision your product touches, the customers who deploy it, and a link to the product or a short description of what it outputs.

Which decision does your product touch?Send us the decision your product touches. You get a free proposal from a software company in Denver with the packet outlined.

Get a free proposal

Get a free marketing proposal

Tell us what you are trying to grow and we will come back with a plan, not a pitch deck. Same-day reply on weekdays.

Privacy Preferences
When you visit our website, it may store information through your browser from specific services, usually in form of cookies. Here you can change your privacy preferences. Please note that blocking some types of cookies may impact your experience on our website and the services we offer.
Contact Us