Colorado’s draft rules and the outside reviewer

Colorado’s interim draft rules offer a practical answer to a small-firm problem.

The draft rules under Colorado’s ADMT Act require a meaningful human review of certain automated decisions, by a reviewer independent of the original decision. At a small firm with one compliance officer, that independence is hard to find in-house.

In August 2026 I filed a comment proposing that a contracted outside reviewer should qualify, under three conditions. On October 6 the Department of Law released an interim draft. Its Rule 8.7 says a qualified external reviewer under contract can satisfy the reviewer requirements if:

1. The Deployer “remains fully accountable for the review.”
2. A contract contains “terms insulating the reviewer’s decisions on individual reviews from the Deployer’s influence.”
3. The Deployer’s oversight of the arrangement addresses administration and performance, not the outcome of any particular review.

Those three conditions closely track the three I proposed. The Department doesn’t say which comments led to which changes, and over sixty were filed, so I can’t know which, if any, shaped the text. If the language survives into the final rules, it could give a small firm a workable route to independent review without building a second compliance team, provided the firm meets all of Rule 8.7’s requirements, not only these three.

On October 14 I filed a supplemental comment asking the Department to keep the external reviewer route, because it is one a small firm can actually use. The draft is interim, not final, and the law takes effect January 1, 2027. The comment deadline and public hearing are October 26, 2026. If your firm may be in scope of Colorado’s ADMT Act, start with whether it applies to you, then read Rule 8.7.

Written for compliance and risk readers in regulated financial firms. Informational, not legal advice; Mike Bidun is not a lawyer.