NIST AI Risk Management Framework: Mapping to Colorado SB 24-205
In This Article
Why NIST AI RMF Matters for Colorado Compliance
The NIST AI Risk Management Framework isn't just a nice-to-have — it's explicitly referenced in Colorado SB 24-205 as a qualifying framework for the affirmative defense. Organizations that demonstrate good-faith alignment with NIST AI RMF receive a rebuttable presumption of compliance.
Released in January 2023 by the National Institute of Standards and Technology, the AI RMF 1.0 provides a structured, voluntary approach to managing AI risks. It's technology-agnostic, scalable from startups to enterprises, and designed to be integrated into existing risk management processes.
GOVERN → Risk Management Policy
The GOVERN function establishes organizational AI governance: policies, roles, accountability, and culture.
SB 24-205 mapping:
- GV.1 (Policies) → Your documented, public-facing risk management policy. Must describe how AI risks are identified, assessed, and mitigated.
- GV.2 (Accountability) → Clear ownership of AI compliance. Who is responsible for bias audits? Impact assessments? AG notification?
- GV.3 (Workforce) → Training records for staff involved in AI governance. SB 24-205 requires competent oversight.
- GV.4 (Culture) → Organizational commitment to responsible AI. Internal communications, training, and leadership engagement.
MAP → AI System Inventory & Classification
The MAP function is about understanding context: what AI systems exist, what they do, and who they affect.
SB 24-205 mapping:
- MP.1 (Context) → Inventory of all AI systems with their purposes, intended uses, and affected populations
- MP.2 (Impact) → Classification of which systems make "consequential decisions" under the statute
- MP.3 (Stakeholders) → Identification of affected consumers and communities
- MP.4 (Risks) → Known risks of algorithmic discrimination for each system, including data bias and proxy variable issues
CO-AIMS implements MAP through its system registry — you register each AI tool, classify its risk level, document its decision scope, and identify affected populations.
MEASURE → Bias Audits & Impact Assessments
MEASURE is about quantifying AI risks through testing, evaluation, and monitoring.
SB 24-205 mapping:
- MS.1 (Testing) → Regular bias audits using statistical methodologies (disparate impact ratio, significance testing, demographic parity)
- MS.2 (Evaluation) → Annual impact assessments documenting system purposes, risks, data sources, and oversight mechanisms
- MS.3 (Monitoring) → Continuous monitoring for algorithmic discrimination, not just point-in-time audits
- MS.4 (Metrics) → Defined thresholds and alerting criteria for bias detection
MANAGE → Incident Response & Remediation
MANAGE covers risk treatment: what you do when issues are found.
SB 24-205 mapping:
- MG.1 (Response) → Incident response procedures for algorithmic discrimination, including 90-day AG notification
- MG.2 (Remediation) → Cure procedures: identify the cause, implement the fix, verify effectiveness
- MG.3 (Communication) → Consumer disclosure mechanisms and appeal/human review processes
- MG.4 (Documentation) → Three-year record retention of all audits, assessments, incidents, and remediations
CO-AIMS ties all four NIST functions into a single platform. Your GOVERN dashboard shows policy status and training completion. MAP is your system registry. MEASURE runs automated bias audits and generates impact assessments. MANAGE handles incident tracking, remediation, and evidence bundle generation.
Frequently Asked Questions
Is NIST AI RMF mandatory for Colorado compliance?
No — NIST AI RMF is voluntary. However, it's explicitly referenced in SB 24-205 as a qualifying framework for the affirmative defense. Following it gives you a rebuttable presumption of compliance, making it strongly recommended even though not mandatory.
What is the difference between NIST AI RMF and ISO 42001?
NIST AI RMF is a U.S. government framework focused on risk management functions (Govern, Map, Measure, Manage). ISO 42001 is an international standard for AI management systems with certification options. Both qualify for Colorado's affirmative defense. NIST is more commonly adopted by U.S. organizations.
How do I demonstrate NIST AI RMF alignment?
Document how each NIST function and subcategory is addressed in your AI governance program. Maintain evidence of implementation: policies, audit results, impact assessments, training records, and incident responses. A gap analysis against each subcategory is the standard starting point.
Automate Your Colorado AI Compliance
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AI Solutionist and founder of CO-AIMS. Building compliance infrastructure for Colorado's AI Act. Helping law firms, healthcare providers, and enterprises navigate SB 24-205 with automated governance.