MEMORANDUM
PHIL WEISER
Attorney General
NATALIE HANLON LEH
Chief Deputy Attorney General
SHANNON STEVENSON
Solicitor General
TANJA WHEELER
Associate Chief Deputy Attorney General
STATE OF COLORADO DEPARTMENT OF LAW
RALPH L. CARR COLORADO JUDICIAL CENTER
1300 Broadway, 10th Floor Denver, Colorado 80203 Phone( 720) 508-6000
Consumer Protection Section
November 24, 2025
MEMORANDUM
TO:
Entities Subject to § 6-1-737, C. R. S. Including Landlords and Property Management Companies
FROM: Colorado Department of Law RE:
Guidance on Enforcement Priorities Related to Utility Billing Under House Bill 25-1090
The Colorado General Assembly enacted House Bill 25-1090(“ CONCERNING PROTECTIONS AGAINST DECEPTIVE PRICING PRACTICES”) in the 2025 Regular Session, which was signed into law on April 21, 2025. H. B. 25-1090, 75th Gen. Assem., 1st Reg. Sess.( Colo. 2025). The new law will go into effect on January 1, 2026(“ Effective Date”). This bill was codified as part of the Colorado Consumer Protection Act(“ CCPA”), with provisions regarding utility billing disclosures codified at § 6-1-737, C. R. S. In light of this new statute and in response to questions regarding the bill’ s provisions and enforcement, the Department of Law(“ Department”) issues the following guidance.
UTILITY BILLING ENFORCEMENT The CCPA, as amended by H. B. 25-1090 will state as of the Effective Date:
A landlord or the landlord’ s agent shall not require a tenant to pay a fee, charge, or amount... [ r ] elated to the provision of utilities that is above the amount charged by the utility provider for service to the tenant’ s dwelling unit, except in accordance with Section 38-12-801( 3)( a)( VI).
§ 6-1-737( 4)( a), C. R. S. This provision is one part of a broader statute, all provisions of which address deceptive pricing practices which might harm consumers.
66 | TRENDS NOV / DEC 2025 www. aamdhq. org