Research update · September 4, 2026
Three changes to read alongside your existing materials.
This reviews the sources and claims below. It does not re-date every library document. Earlier PDFs retain their edition dates; use this note where their descriptions conflict.
Illinois: separate the statute from proposed procedure.
HB 3773 took effect January 1, 2026. It addresses discriminatory effects from covered employment-AI use, ZIP-code proxies and notice. The statute authorizes implementing rules. See Public Act 103-0804.
IDHR’s May 15 proposed notice rules were formally withdrawn in the June 26 Register, at 50 Ill. Reg. 8755. Their specific timing, format and recordkeeping provisions are not adopted requirements. See the official withdrawal notice.
Our recommendation: map notices to actual uses, record ownership and keep versions. Serving a notice before the relevant step is an operating discipline in our templates; do not present it as a universally adopted HB 3773 timing rule. Have counsel resolve applicable notice, consent, accommodation and retention requirements.
European Union: the Omnibus is enacted.
Regulation (EU) 2026/1744 was published July 24 and entered into force July 27. Covered Annex III high-risk duties move to December 2, 2027; the corresponding Annex I date is August 2, 2028. The amendments also change substantive provisions.
Article 50 generally applies from August 2, 2026. A specific transition gives providers of covered content-generation systems placed on the market before that date until December 2, 2026 to meet Article 50(2). This is not a blanket extension of transparency duties. Read Article 1(39)–(40) and Article 4 of the enacted regulation.
Colorado: more than a disclosure change.
SB 26-189, signed May 14, replaces the earlier framework. Its provisions include developer documentation, records, disclosures and consumer review mechanisms, with principal duties scheduled for January 1, 2027. Scope and duties differ by role and use; the Colorado legislature’s enacted-bill summary provides the source for this overview.
TalentSight: vendor question numbering.
The current PDF response tracker has inconsistent short labels. Until its replacement is issued, use the questionnaire as the numbering authority: Q2 is inputs and training data; Q5 is name, voice, image and identifiers; Q8 is recordkeeping; Q12 is sub-processors and downstream models. Completeness measures the response, not compliance.
Scope: these three regulatory updates and the tracker correction only. Other jurisdictions, litigation statistics and insurance-market claims were not comprehensively reverified. This educational summary supports review with your own counsel.
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