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State AI Law Tracker for Credit Unions

The state AI and privacy laws most likely to affect credit unions, what each one requires, their status, and when each takes effect.

Financial Services · Credit Unions and Lenders · Prepared by the Cogent Assurance team

The short answer

Most state AI laws affecting credit unions fall into three groups: rules on automated decisions in lending and other consequential decisions, such as Colorado’s; rules on AI in hiring, such as Illinois’s and New York City’s; and disclosure rules for AI interactions, such as Utah’s. Many state privacy laws exempt GLBA-covered institutions or data, but AI laws often have narrower exemptions, so each must be checked for credit unions with members or employees in that state.

Status at a glance

Colorado

Automated decisions

Effective soonJan. 1, 2027

California

Automated decision rules under the CCPA

Effective soonJan. 1, 2027

Illinois

AI in employment decisions

In effectJan. 1, 2026

Texas

Responsible AI Governance Act

In effectJan. 1, 2026

Utah

AI interaction disclosures

In effect2024, amended 2025

New York City

Bias audits for hiring tools

In effect2023

What each law means for credit unions

JurisdictionLawWhat it coversWhat credit unions should do
ColoradoSB 26-189Automated decision-making technology in consequential decisions, including lendingPrepare disclosures and post-decision explanations for Colorado members.
CaliforniaCCPA automated decision-making regulationsNotices, opt-outs, and access rights for certain automated decisionsConfirm which data falls outside your GLBA exemption, such as marketing and employee data.
IllinoisAmendments to the Illinois Human Rights ActDiscrimination and notice when AI is used in employment decisionsReview AI hiring and HR tools and give the required notice to Illinois employees and applicants.
TexasTexas Responsible AI Governance ActProhibited AI practices and government AI useConfirm no AI use falls into a prohibited category.
UtahUtah Artificial Intelligence Policy ActDisclosure that a consumer is interacting with generative AI in certain situationsDisclose chatbot use to Utah members, especially when asked.
New York CityLocal Law 144Independent bias audits and notices for automated hiring toolsAudit any automated hiring tool used for New York City positions.

Upcoming dates

  1. Jan. 1, 2026

    Illinois and Texas

    Illinois employment AI rules and the Texas Responsible AI Governance Act take effect.

  2. Jan. 1, 2027

    Colorado and California

    Colorado’s automated decision rules and California’s automated decision requirements take effect.

  3. Ongoing

    New legislation

    Several states consider new AI bills each session. We update this tracker as laws pass.

Frequently asked questions

Do GLBA exemptions cover state AI laws?

Not always. Many state privacy laws exempt GLBA-covered institutions or data, but AI-specific laws often have narrower exemptions or none, and employee data is usually outside GLBA entirely.

Which laws apply to a credit union with members in many states?

Generally, the laws of the states where your members or employees are located, not just where you’re headquartered. Start with the states where you have the most members and staff.

More Guides for Credit Unions and Lenders

Sources

  • Colorado SB 26-189 (2026)
  • California Consumer Privacy Act regulations on automated decision-making technology
  • Illinois Human Rights Act, as amended by HB 3773
  • Texas Responsible AI Governance Act, HB 149 (2025)
  • Utah Artificial Intelligence Policy Act, as amended
  • New York City Local Law 144 of 2021

How this guide is built

Built from primary sources: statutes, regulations, standards, and agency guidance. Our team reviews each industry’s legal summary every quarter and updates guides when requirements change.

Cite this guide

Cogent Assurance. (2026). State AI Law Tracker for Credit Unions. Cogent Assurance Resource Center. https://cogentassurance.com/resources/state-ai-law-tracker-credit-unions

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This guide is general information for planning purposes. Laws and guidance change, so confirm current requirements before acting. It is not legal advice. For legal advice about your organization, consult a licensed attorney.

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