AI Policy Defined: Deployers & High-Risk Systems
Key highlights this week:
We’re tracking 1,136 bills in all 50 states related to AI during the 2025 legislative session (which now includes some prefiled bills for the 2026 sessions).
AGs in North Carolina and Utah announce the formation of a bipartisan AI Task Force.
New York’s AG announces that the state’s algorithmic pricing disclosure regulation took effect this month.
And as the 2025 legislative sessions wrap up, we’ll take a step back and review critical definitions used by policymakers to regulate AI, such as Colorado’s AI law, which is the topic of this week’s deep dive.
Artificial intelligence regulation is beginning to take shape in the states, but with different approaches. California’s first-in-the-nation AI safety law targets the largest developers, requiring transparency and safety reporting for so-called “frontier models.” Colorado’s law, which is set to take effect in June 2026, instead focuses on “high-risk” systems and creates obligations for both the developers who build them and the deployers who use them to make “consequential decisions.” Additional laws more narrowly focus on specific use cases of deployer use of AI. What these and other efforts have in common is that they hinge on how lawmakers define the scope of regulation.
This week, we’ll begin a multi-part series examining how enacted laws define important terms in AI policy. This first article will focus on the “deployers” and “integrators” of artificial intelligence models. Next week, we will focus on definitions relating to model-developer regulation.
For companies adopting AI tools, one of the most important questions under recent state laws is whether they count as a “deployer” of artificial intelligence. Colorado’s law (CO SB 205) doesn’t just regulate model developers; it imposes obligations on businesses that use AI systems in ways that can materially affect people’s lives. That means a bank using an algorithm to screen loan applicants, an HR platform reviewing resumes, or even a landlord applying automated tenant scoring could all fall within the scope of a “deployer” under these laws.
