from these obligations, but are instead prohibited from itemizing these costs to a tenant. The challenge that this creates for landlords is how to adjust the pricing of their product.
HB 25-1090 has requirements on pricing. It requires landlords to disclose up front the total cost of the lease to the tenant in advertising. The total price approach is designed to promote transparency, and markups on any services provided to a tenant have to be disclosed to tenants. The purpose of the transparency will have an impact on how properties are advertised, but it should also promote competition for landlords with regard to pricing.
The power of HB 25-1090 forcing the disclosure of total price has the potential to transform the current marketplace, where total price may not be easy for tenants and other landlords to identify. With the requirement to disclose all fees, there is going to be a lot of competition towards minimizing separate fees.
This new law requires a careful examination of advertising practices, and your leasing documents to ensure compliance by January 1, 2026. In addition, landlords should re-visit their billing practices to ensure that they are complying with the limitations on markups of third party services, and not exceeding the $ 10 or 2 % markup cap.
There have been efforts at the federal level to clarify that the CARES Act provisions related to eviction notices have expired. For those in Colorado that operate a CARES covered property, those efforts are now meaningless, due to HB25-1240. Colorado has codified the
CARES act so that a covered property will remain covered and subject to the 30 day notice requirements for non-payment of rent regardless of what happens at the federal level. This will not be an operational change for landlords that are already covered by the CARES act. It just means that the burden of dealing with additional cure time periods will not be going away in Colorado. The impact of this will be felt in the future, if the CARES act is changed at the federal level, Colorado will be less attractive for investing in new housing due to the additional cost property owners will face when dealing with a delinquent tenant. The other more immediate impact of this bill is that it forces landlords to comply with rental assistance efforts, or face monetary consequences for discriminating against tenants. Many times landlords comply with rental
16 | TRENDS AUGUST 2025 www. aamdhq. org