Other States and the EU: AI Laws That Reach Texas Companies

Short Answer

A Texas company can meet other jurisdictions’ AI rules through its customers, applicants, employees or operations. Colorado’s 2026 automated decisionmaking technology (ADMT) act has principal requirements scheduled for January 1, 2027. California privacy and employment regulations have different scopes and phased dates. Illinois employment provisions took effect January 1, 2026; New York City regulates covered hiring tools. EU coverage and deadlines depend on the provider or deployer role and the system category. A common governance record can support several analyses, but it does not replace checking each jurisdiction’s elements and exemptions.

Which Laws Apply

Texas AI-specific: the Texas Responsible Artificial Intelligence Governance Act (TRAIGA) for Texas activity.

Generally applicable Texas law: choice of law and contract terms with out-of-state customers.

Other jurisdictions: the laws below, depending on where customers, applicants and users are.

Major State Laws

The EU AI Act

EU AI Act coverage follows Article 2, including certain non-EU providers and deployers whose output is used in the EU, with statutory exceptions. The original Chapter II prohibitions began applying February 2, 2025 and general-purpose AI provisions followed August 2, 2025. Regulation (EU) 2026/1744 entered into force July 27, 2026. The amendment added two Chapter II prohibitions that apply December 2, 2026, not at entry into force: Article 5(1)(ba) bars AI systems that generate or manipulate nonconsensual intimate imagery of an identifiable person, and Article 5(1)(bb) bars AI systems that generate or manipulate child sexual abuse material. Provider duties are qualified: placing on the market or putting into service is barred only where that generation or manipulation is the system’s intended purpose or a reasonably foreseeable and reproducible outcome without adequate technical safeguards, and deployer use is barred only where the deployer uses the system for that purpose. Separately, the amendment moved the principal Chapter III high-risk requirements to December 2, 2027 for Article 6(2) and Annex III systems, and August 2, 2028 for Article 6(1) and Annex I systems. Article 50 transparency requirements retain the general August 2, 2026 application date. A Texas company should identify its role and use case before applying a single AI Act deadline.

Building One Program for Many Laws

Most of these laws share a structure: know which systems make or shape consequential decisions, tell people when AI is used, let them correct data or reach a human, test for discrimination and keep records. A Texas company that builds its governance program around those elements, and around the documentation TRAIGA’s defenses reward, will be closer to compliance in several states at once. See AI Governance Programs and the TRAIGA Defenses.

Illustrative Example (Hypothetical)

Hypothetical: a Texas staffing firm uses a screening tool for clients in Texas, Illinois and New York City. Federal and Texas employment law apply to covered Texas uses. Covered Illinois uses add notice requirements; covered New York City tools add independent audit, public-summary and notice rules. The firm should test each rule’s definitions, actors and exceptions before choosing a common process. A single national process can be useful, but the strictest label alone does not establish compliance everywhere.

What Is Unsettled

Whether Colorado’s amended law takes effect on schedule, given federal intervention in litigation; how California’s ADMT opt-out will work in employment; and whether a national framework will preempt some or all of these laws.