Key point: Vermont’s legislature passed a consumer data privacy bill, Illinois’ legislature passed an AI frontier model bill, and eight bills crossed chambers in California.

Below is the 20th update on the status of proposed state privacy and AI legislation in 2026. With state legislative activity slowing, we have combined our weekly privacy and AI posts.

In this episode of The Consumer Finance Podcast, Chris Willis and Kim Phan unpack Colorado’s brand-new Automated Decision-Making Technology (ADMT) Act, which repeals and replaces the state’s much-criticized 2024 AI law. They explain the shift from “high-risk AI systems” to the broader ADMT framework, what it means for consequential decisions in lending and financial services, and how the statute’s “material influence” standard can sweep in tools that do far more than make final credit determinations.

Key point: Connecticut’s new AI law adds to the growing complexity of state laws directed at commonly used automated employment decision tools.

On May 27, 2026, Connecticut Governor Ned Lamont signed SB 5 into law. Connecticut Senator James Maroney authored the bill, which covers several different areas involving the regulation of artificial intelligence (AI), including frontier models, chatbots, employment, and provenance. Lamont also signed into law a companion bill, SB 4, which amends Connecticut’s consumer data privacy law and establishes a data broker registration law. Altogether, the two bills significantly redefine the state’s privacy law and introduce requirements for the use of AI.

In the coming weeks, we will be posting articles analyzing several of the key aspects of these bills. In this first article, we analyze SB 5’s provisions as they relate to the use of automated employment decision technologies (AEDT).

Key point: In response to an open records request submitted by Troutman Pepper Locke, the New Jersey Attorney General’s office provided copies of all cure letters sent pursuant to New Jersey’s consumer data privacy law and resolved by the recipient.

As shown by recent enforcement actions in California, including its most recent $12.5 million fine, the risk for companies that are out of compliance with state consumer data privacy laws has never been higher. As more state laws go into effect and cure periods sunset, the risk will only grow. One state where the enforcement risk may be higher is New Jersey.

Key point: Louisiana’s legislature passed a consumer data privacy bill, five bills crossed chambers in Illinois, nine bills crossed chambers in California, and Delaware’s House passed a bill to significantly amend the state’s consumer data privacy law.

Below is the 19th update on the status of proposed state privacy and AI legislation in 2026.

Key point: (1) Plaintiffs who expand their class definition beyond the complaint risk losing both certification and their class representative on limitations grounds; (2) Banners that require users to interact before accessing website may be sufficient to establish consent; (3) What makes tracking “highly offensive” is becoming clearer; (4) the “in transit” requirement continues to divide courts; (5) Courts demand more than labels to survive a standing challenge.

As lawsuits and regulatory scrutiny targeting “data brokers” continue to accelerate, understanding whether your organization fits within this increasingly broad industry space is a critical risk management priority. The stakes have never been higher for entities that collect, enrich, or license data to understand the evolving causes of action, damages theories, and defense strategies shaping this space.