COLORADO LEGISLATION · PROPERTY MANAGEMENT
By Pioneer Property Management · Updated May 2025 · 7 min read
As of January 1, 2026, Colorado’s House Bill 25-1090 changes the rules around how rental pricing must be advertised and disclosed across the state. Officially titled the Protections Against Deceptive Pricing Practices Act, it’s designed to protect renters from the kind of hidden fees that make a “great deal” feel a lot less great by the time you’re signing a lease.
If you own or manage rental property in Colorado, this law affects you directly – from how you list units to how you structure fees and communicate costs with prospective residents. Here’s what you need to know to ensure compliance.
Effective Date: January 1, 2026. Any rental advertised or leased on or after that date must comply with HB 25-1090’s total price disclosure requirements.
What Is House Bill 25-1090?
HB 25-1090 was signed into law in April 2025 as part of a national push to end “drip pricing” – the frustrating practice of advertising a low base price and then tacking on mandatory fees as the transaction moves forward. Colorado’s law spans several industries, but the impact on residential rental property owners and managers is where it really hits home.
The law came about because renters were tired of it. You see a listing for $1,400/month, get excited, start the application – and by the time you’re at the lease, the real monthly cost is $1,600 or more once you add administrative fees, amenity charges, utility billing fees, and other mandatory costs. That gap between advertised price and actual cost is exactly what this law is meant to close.
Under HB 25-1090, that practice is no longer legal in Colorado.
The Core Requirement: Total Price Disclosure
The heart of the law is simple: every advertisement, listing, or communication about a rental must show the total price – one all-in number that includes every mandatory monthly charge a resident will pay to lease and live in the property.
That total price also has to be the most prominent number in your listing – not buried in fine print, not disclosed only at lease signing. Front and center.
WHAT MUST BE INCLUDED Base rent, mandatory amenity fees, required parking fees, mandatory utility billing service fees, and any other charges a tenant must pay to move in and live in the unit.
WHAT MAY BE EXCLUDED Government-imposed taxes or charges (e.g., city lodging taxes), truly optional services the tenant can choose to add or decline, and tenant-selected utility usage.
Before vs. After: A Practical Comparison
| Scenario | Before HB 25-1090 | After HB 25-1090 |
| Zillow/Apartments.com listing with $50 mandatory amenity fee | Advertise $1,200/mo | Must advertise $1,250/mo |
| Mandatory $10/mo utility billing admin fee | Disclose at lease signing | Include in advertised total |
| Optional pet fee for tenants who have pets | Variable practice | May remain separate (optional) |
| Required parking with no street alternatives | Sometimes listed separately | Must be included in total price |
| Itemized service fee markup | Unregulated | Capped at 2% of actual cost or $10/mo (whichever is less) |
What Counts as “Mandatory”?
This is the most important – and honestly the most debated – question under the new law. A fee is mandatory if a resident must pay it to lease and live in the property, regardless of what you call it. The law is specifically targeting the practice of labeling required charges as “optional” to keep advertised rents looking lower than they really are.
Here are the types of fees that will almost certainly qualify as mandatory and need to be rolled into your total price:
- A “community amenity fee” charged to all residents regardless of whether they use amenities
- A utility billing administration fee charged to every tenant on every bill
- A required trash valet fee for all residents in a community
- A mandatory renters insurance enrollment fee charged by the landlord
- Required parking in a building or neighborhood where street parking isn’t available
On the other hand, a pet fee for a resident who chooses to have a pet, or an add-on storage unit fee, can generally stay separate – as long as they are genuinely optional and residents can say no.
The 2% / $10 Markup Cap
The law goes a step further on itemized services, and acts as a supplemental bill to HB 23-1095. When you pass through a cost for something like a utility billing platform fee or a pest control charge – and mark it up – that markup is now capped at:
2% of actual cost OR $10 per month – whichever is less. This is meant to stop pass-through services from becoming a quiet profit center. If your property management software charges $5/month per unit for utility billing, you can’t turn around and charge residents $20/month for that service.
What Happens If You Don’t Comply?
Violations fall under deceptive, unfair, or unconscionable pricing practices under Colorado consumer protection law – which carries real teeth. Residents harmed by non-compliant pricing may be entitled to civil remedies, including damages of up to three times actual damages or between $100 and $1,000 per violation.
Formal enforcement guidance from the Colorado Attorney General’s office is still taking shape, but the exposure is real – especially as tenant advocacy continues to grow in Colorado’s rental market.
Property Manager Compliance Checklist
Here’s what owners and managers should work through before January 1, 2026:
- Audit every fee currently charged to residents – categorize each as mandatory or optional.
- Calculate a true “total price” for each active listing and unit type.
- Update all rental listings on Zillow, Apartments.com, Craigslist, and your own website to reflect the total price.
- Review lease templates to ensure all mandatory fees are disclosed clearly and match the advertised total.
- Audit any utility billing or RUBS (Ratio Utility Billing System) arrangements for markup compliance.
- Review any fees currently labeled “optional” to confirm they’re genuinely opt-in – not de-facto required.
- Train leasing staff or update internal procedures to reflect new disclosure requirements.
What This Means for Tenants
For residents and prospective renters, this law is a genuine win. It means that when you’re comparing a $1,600/month listing on one property against a $1,600/month listing on another, you’re comparing apples to apples – not just base rent against base rent.
Frequently Asked Questions
Does HB 25-1090 apply to single-family rentals or only apartment communities?
The law applies broadly – single-family rentals, small multi-unit buildings, and large apartment communities alike. If you’re advertising a rental in Colorado and charging mandatory fees, total price disclosure is required, regardless of property type.
What if a fee varies by unit – like assigned vs. unassigned parking?
If parking is mandatory for all residents – even if the specific stall varies – it needs to be included in the total price. If parking is genuinely optional and residents can choose to park on the street instead, it can be listed separately with clear labeling.
Do lease renewal listings also need to comply?
Yes. Any time a rental price is communicated in an advertisement or offer – including renewal offers – the total price disclosure requirements apply. That said, leases signed before 1/1/2026 remain valid and aren’t affected until renewal time.
How does this interact with RUBS (ratio utility billing)?
RUBS charges vary based on actual usage, so the variable portion can generally be excluded from the total price. However, any fixed administrative or service fee that’s charged as part of the RUBS billing process – and is mandatory – needs to be included.
Is there an enforcement grace period after January 1, 2026?
The Colorado AG’s office is still finalizing its enforcement guidance. But the statutory effective date is January 1, 2026, and civil remedies are available to residents from that date forward. Waiting for formal enforcement guidance before getting into compliance is a risk we wouldn’t recommend taking.
How Pioneer Property Management Is Preparing
At Pioneer Property Management, staying current with Colorado’s rental regulations isn’t a once-a-year exercise – it’s core to how we protect the owners we work with. Ahead of the January 1 deadline, we completed a full audit of all managed listings and fee structures, updated listing templates across all platforms, and reviewed lease agreements to confirm full compliance with HB 25-1090.
If you self-manage, the steps required are workable – but they take intentional review. If you’re not sure whether your current fee structure holds up under the new law, or you’d simply rather hand that off to a team that’s already done the work, we’re happy to help.
