AI in hiring · records and notices · updated
The 30-day explanation after an adverse decision
From 1 January 2027, when an AI tool materially influences a hiring decision that goes against a Colorado applicant, the employer has 30 days to explain it: what was decided and the role the tool played, how to ask for the tool's name, version, developer and the personal data it used and where it came from, and the applicant's rights to correct their data and to ask a person to review the decision. This is separate from the adverse action notice the Fair Credit Reporting Act requires when a background check is used.
What the law says
“If a deployer uses a covered ADMT to materially influence a consequential decision that results in an adverse outcome for a consumer, the deployer shall provide within thirty days after making the decision: (a) a plain language description of the consequential decision and the role the covered ADMT played in the consequential decision; (b) instructions and a simple-to-follow process to request additional information about the covered ADMT and the inputs, including the name of the covered ADMT, the covered ADMT version number, if applicable, the covered ADMT developer, and the types, categories, and sources of personal data used …; and (c) an explanation of the consumer rights described in section 6-1-1705 and how to exercise them.”
C.R.S. 6-1-1704(3)
Proposed, not final: the Colorado Attorney General's draft rules (4 CCR 904-6, filed 11 August 2026, revised 23 September and 6 October; hearing 26 October 2026) ask for the principal reasons stated with specificity, the explanation delivered through at least two of the channels normally used with the person, and a request for review acknowledged within 10 days and completed within 45. The final rules are due by 1 January 2027.
Vague declines
Decline emails are often deliberately vague. Anthropic's hiring-screener skill, for one, advises "Kind and vague beats specific and untrue" (skill text). Where Colorado's explanation is due, the proposed rules ask for the principal reasons stated with specificity. The reasons have to be yours: only you know them.
The template
The explanation
Within 30 days of the decision. Record the date you sent it and how.
About the decision on your application for [role] Dear [name], On [date of the decision] we decided [what was decided, e.g. not to move your application forward]. This letter explains the part automated decision-making technology played in that decision. The role the technology played: [tool name], made by [who makes it], was used in [where it is used, e.g. resume screening]; it [what it does with each application]. [Who reviews its output] reviewed its output before the decision and could change the outcome. [Say how much its output counted, and what else was considered.] The principal reasons for the decision: - [The first principal reason, stated specifically] - [The next principal reason, if any] More information about the technology: [tool name], version [version, if the vendor gives one], made by [who makes it]. The personal data it used: [the personal data it uses], from [where that data comes from]. To ask for more information about it and about the information it used, contact [contact email or page]. Your rights: - You can ask for the personal data used in this decision, and ask us to correct any that is factually incorrect or materially inaccurate. - You can ask for a person to review and reconsider this decision. The reviewer can change it. To use either right, contact [who handles review requests]. If you need this in another format or language, or an accommodation in the application process, contact [contact email or page]. [Your business name], [date]
When someone asks for a review
The review procedure
Based on the act's definition of meaningful human review (6-1-1701(15)).
Human review and reconsideration: our procedure Who reviews: [name or role], designated by [Your business name], with authority to approve, change or overturn the decision. Requests go to [who handles review requests]. Before reviewing, the reviewer: - has been trained to do this review: [the training, and when it was given]; - has the tool's intended use, its material limitations and the categories of data it uses: [where the vendor's documentation is kept]; - understands the principal factors behind the tool's output for this applicant. In the review, the reviewer: - considers the relevant primary evidence available, such as the application itself, not only the tool's output; - does not default to the tool's output; - records the outcome (upheld, changed or overturned) and the reasons, in the human-review log. Timing: we acknowledge a request within [10] days and complete the review within [45] days. [These are the proposed rule's periods; check the final rules.] Each request, the review and its outcome are kept for at least [3] years after the decision.
All of it, filled in from your own files, free
$ npx --allow-git=root github:agentwares/hiringrecord kit --ats your-ats-export.csvAn inventory of the AI tools in your hiring from your answers and your applicant-tracking export, the notices for each law that applies, the 30-day explanation and the review procedure, a risk-assessment worksheet and what to keep, as dated files with a SHA-256 manifest. Runs on your machine: no account, no upload, no AI. Also a Claude plugin and a local MCP server: github.com/agentwares/hiringrecord.
A continuous, hash-chained record of every hiring decision your AI tools touched, kept for the years the law asks, is not built
It would record each decision as it happens (the tool and its version, the outcome, the reviewer, the explanation sent and its date, review requests and what came of them) in okgate's hash-chained log, keep it three years for Colorado or four for California, track each 30-day clock, and export it for your counsel.
What exists today: the templates on these pages, which you keep yourself. okgate keeps a hash-chained log of the tool calls AI agents make through its proxy, not hiring decisions.
Sources, each read on 9 October 2026
- Colorado SB 26-189 as signed, 14 May 2026 (C.R.S. 6-1-1701 to 6-1-1709)
- Byte Back: Colorado Attorney General releases proposed rules for the ADMT Act (19 Aug 2026)
- Cyber Adviser: revised draft rules for the Colorado ADMT Act released (7 Oct 2026)
- Baker Botts: Colorado's draft ADMT rules, what employers should know (Sep 2026)
- anthropics/knowledge-work-plugins: the Small Business plugin's hiring-screener skill (15 Sep 2026)