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Colorado — HB 25-1090

Colorado's Protections Against Deceptive Pricing Practices

HB 25-1090 requires Colorado businesses to clearly and conspicuously disclose the maximum total price up front. Effective January 1, 2026, it covers hospitality, food service, broadband, delivery platforms, real estate, and rental housing.

Effective
January 1, 2026
Citation
C.R.S. tit. 6 (Colorado Consumer Protection Act amendments)

What HB 25-1090 requires

Colorado's HB 25-1090, the Protections Against Deceptive Pricing Practices Act, was signed by the Governor on April 21, 2025 and takes effect January 1, 2026. It requires businesses to "clearly and conspicuously disclose the maximum total" — the total price — of all amounts a person may pay for a good, service, or property.

The act also prohibits misrepresenting pricing information and requires clear disclosure of any charge that is not included in the disclosed total, with an explanation of when and how that charge will be calculated.

Industries covered (and accommodations)

HB 25-1090 applies broadly to consumer transactions, but several industries received tailored carve-outs to address legitimate operational realities:

  • Food and beverage establishments — mandatory service charges may be permitted with conspicuous disclosure.
  • Broadband, cable, and satellite providers — total price disclosures aligned with FCC requirements.
  • Delivery network companies — fees may be percentage-based with clear pre-checkout disclosure.
  • Real estate settlement services — settlement-cost disclosures align with federal RESPA practices.
  • Businesses with indeterminate pricing — must disclose the methodology and any minimum or maximum.
  • Residential rentals — landlords cannot require tenants to pay prohibited junk fees or include them in lease provisions (building on HB 23-1095 limits on rental mark-ups).

Penalties and enforcement

Violations of HB 25-1090 are deceptive trade practices under the Colorado Consumer Protection Act (C.R.S. § 6-1-105 et seq.). A person harmed by a violation may send a written demand to the alleged violator. If the violator declines to make full legal tender or to cease the conduct within 14 days of the written demand, the violator is liable for actual damages plus 18% interest, compounded annually. The Colorado Attorney General and district attorneys may also pursue civil penalties, restitution, and injunctive relief.

Private plaintiffs may sue for actual damages, treble damages in some circumstances, and attorneys' fees.

Relationship to existing Colorado law

HB 23-1095 (signed 2023) already restricted residential-rental "junk fees" — capping mark-ups on third-party costs and limiting fee provisions in residential leases. HB 25-1090 broadens the framework beyond housing to general consumer pricing.

Colorado has historically also enforced pricing transparency under the existing Colorado Consumer Protection Act, particularly against hospitality and short-term rental operators advertising rates that excluded mandatory cleaning, resort, or service fees.

Frequently asked questions

When does Colorado HB 25-1090 take effect?

January 1, 2026. Businesses operating in or selling to Colorado consumers should plan compliance updates well in advance of that date.

What does "maximum total" mean under HB 25-1090?

The maximum total is the upper bound of what a consumer may pay, including all mandatory fees. For services with variable pricing — for example, time-based or use-based fees — the law requires clear disclosure of the methodology and any minimum or maximum.

Are restaurants exempt from HB 25-1090?

No, but the law includes accommodations for food and beverage establishments. Mandatory service charges may be permitted if clearly and conspicuously disclosed with their purpose. The structure parallels California's SB 1524 carve-out.

How does HB 25-1090 interact with the FTC junk fees rule?

The FTC's federal rule (16 C.F.R. Part 464) applies only to live-event ticketing and short-term lodging. HB 25-1090 is broader, covering most consumer transactions in Colorado. Businesses in the FTC-covered sectors must comply with both.

What about HB 23-1233 — wasn't that the junk fee bill?

No. Colorado HB 23-1233 (2023) addressed electric-vehicle charging and parking requirements, not junk fees. The relevant Colorado pricing-transparency laws are HB 23-1095 (residential rental fees) and HB 25-1090 (general consumer pricing). This is a common confusion in secondary sources.

Sources

Statutes, regulations, and official agency guidance referenced on this page. Primary sources are statutes or codified rules; agency guidance reflects how regulators interpret those rules.

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This page is an educational summary, not legal advice. Statutes and regulations change. Confirm current text with the linked primary sources and consult qualified counsel for decisions about your business.