Blog/Compliance Q&A, Vol. 1: AI Policies, Subcontractor Insurance, and the SB24-174 Deadline
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Compliance Q&A, Vol. 1: AI Policies, Subcontractor Insurance, and the SB24-174 Deadline

June 6, 2026 ยท The E&F Compliance Team

Welcome to our first Compliance Q&A.

We hear the same questions again and again from small business owners and local governments, so we're going to start answering them here, in plain English. The questions come from readers, and we always keep them anonymous. Have one of your own? There's a form at the bottom of our blog, and we may answer it in a future edition.

Here are three to start.

"Do I really need a written AI policy for my Colorado brokerage?"

If your brokerage uses AI tools that influence consumer decisions, this is worth taking seriously. Colorado replaced its original AI law with SB 26-189, which takes effect January 1, 2027. It is lighter than the old version, but it keeps duties around consumer notice, disclosure after an unfavorable outcome, and recordkeeping for tools that materially influence consequential decisions, a category that includes housing.

A written policy is not just paperwork. It is how you show, if anyone ever asks, that your brokerage thought about its AI use and put guardrails in place. The time to build it is now, while you have runway before the effective date.

We walk through the details in Colorado's New AI Law (SB 26-189), and the Colorado Real Estate AI Policy Starter Kit gives you an editable policy to start from.

"A subcontractor's insurance expired in the middle of a job. Am I still covered?"

Probably not, and that is exactly the problem. A certificate of insurance is a snapshot of coverage on the day it was issued. Policies lapse and get cancelled on their own schedules, so a COI you collected at onboarding can be worthless months into a project.

The fix is not collecting more certificates. It is watching expiration dates so a renewal request goes out before the old coverage lapses, not after a claim shows up. One simple tracker that flags what is expiring prevents most of these surprises.

More on the system in How to Track Subcontractor COIs, W-9s, and Licenses, and the Construction Subcontractor Tracker does the flagging for you.

"Does my small town actually have to do a housing needs assessment?"

Quite possibly. Colorado's SB24-174 requires jurisdictions of 1,000 or more residents to complete a local housing needs assessment, or participate in a regional one, and submit it to the Department of Local Affairs by December 31, 2026. There are limited exceptions, including for jurisdictions with a negative population change.

If you are not sure whether your town is subject, or which path applies, that is a common spot to get stuck. Confirming it is part of what our SB24-174 HNA Pathway Review is built to answer, and Is Your Municipality Grant-Ready? covers the bigger readiness picture.

Have a question?

That is the whole idea behind this series. If there is something you have been wondering about, send it our way through the form on our blog or at team@efcompliance.com. We answer them here, always anonymously, so your question may help the next owner or town with the same one.


_This article is for general educational purposes only. It is not legal advice or a substitute for the current statutes, rules, your own policies, or a qualified advisor. Requirements change and vary by situation. Verify what applies to you before you rely on this. E&F Compliance Services does not guarantee any outcome._

_E&F Compliance Services helps small business owners and local governments navigate getting compliant and staying compliant, across real estate, construction, transportation, and local government. Reach out at_ _team@efcompliance.com__._

_The E&F Compliance Team_