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Utah’s Artificial Intelligence Policy Act (SB 149) took effect on May 1, 2024, making it one of the first state laws in the US to specifically address generative AI. It is narrower in scope than it is sometimes assumed to be: it does not establish a broad framework for regulating high-risk automated decision-making, the way Colorado’s AI Act does. Instead, it is primarily a consumer-disclosure statute.
What the law covers
The Act applies to the use of generative AI to interact with consumers in Utah. Under the law as originally enacted in 2024, a person or business using generative AI to communicate with a consumer must disclose that fact if the consumer asks — the disclosure obligation is triggered on request, not proactively in every interaction. Failing to make that disclosure when required is treated as a violation addressed through Utah’s existing consumer-protection statutes, rather than under a separate AI-specific penalty scheme.
A 2025 amendment (SB 226, effective May 7, 2025) tightened this baseline for higher-stakes interactions — those involving health, financial, or biometric data, or the provision of advice on financial, legal, or healthcare matters — introducing stricter disclosure obligations for that narrower set of use cases rather than for generative AI use generally.
The Act also created the Office of Artificial Intelligence Policy to oversee implementation, and a regulatory sandbox program (the AI Learning Laboratory Program) that lets participating businesses test AI-related products and services under a modified regulatory framework.
How it compares to Colorado’s AI Act
Utah’s law and Colorado’s AI Act are frequently grouped together as “state AI laws,” but they regulate different things:
- Scope: Utah’s Act is a disclosure requirement tied to generative AI use in consumer interactions. Colorado’s law regulates developers and deployers of automated decision-making technology used in high-stakes decisions — education, employment, housing, lending, insurance, healthcare, and government benefits — regardless of whether the technology involves generative AI at all.
- Obligations: Utah requires disclosure, on request under the original 2024 text and proactively for a defined set of high-risk interactions under the 2025 amendment. Colorado requires developers to supply technical documentation and deployers to give consumers notice and, in some cases, a plain-language explanation of adverse decisions.
- What isn’t in Utah’s law: Utah’s Act does not carry a discrimination-prevention framework comparable to the one originally proposed in Colorado, and it does not impose documentation or audit duties on AI developers.
- Effective dates: Utah’s Act took effect May 1, 2024, with the SB 226 amendment effective May 7, 2025. Colorado’s current law takes effect January 1, 2027.
For businesses operating in both states, the practical distinction is that Utah compliance is largely a disclosure question — what you tell a consumer, and when — while Colorado compliance depends on whether a system falls within the law’s definition of high-risk automated decision-making, which triggers a more involved documentation and notice regime.
How CASRAI’s NIKOLAI tracks this
Utah’s Act sits outside the frontier-model regimes NIKOLAI is built around — it’s a general consumer-disclosure statute triggered by any generative AI interaction, not a compute-threshold-triggered frontier AI framework requirement. But the same underlying pattern — what gets disclosed, to whom, on what trigger — is exactly what CASRAI’s own NIKOLAI project catalogs in more specialized form for frontier developers: Track N8 (Transparency and Review) defines elements like Redaction, Redaction Reason, and Evaluator Access Attestation, which structure what a frontier developer discloses about its own safety evaluations and why any of it might be withheld. NIKOLAI is CASRAI’s own independent, unendorsed reference dictionary — nothing here implies Utah’s Office of Artificial Intelligence Policy has reviewed or adopted any of it. See NIKOLAI Track N8: Transparency and Review or the full dictionary at casrai.org/nikolai.
