Colorado's New Price Transparency Law: What Landlords Need to Know About C.R.S. 6-1-737

As of January 1, 2026, Colorado landlords are operating under one of the most comprehensive pricing transparency laws in the country. House Bill 25-1090, now codified as C.R.S. § 6-1-737, fundamentally changes how residential rental properties must be advertised and how fees can be charged to tenants. If you own or manage rental property in Colorado, understanding this law is no longer optional—it's essential to avoid significant liability.

What Is C.R.S. § 6-1-737?

Colorado's legislature passed HB 25-1090 to eliminate “drip pricing”—the practice of advertising a low base price and then adding mandatory fees later in the transaction. While the law applies broadly to many industries, it contains specific provisions targeting residential landlords. The stated purpose is to ensure renters can understand the true cost of housing without navigating through layers of additional charges.

The “Total Price” Requirement

Under the new law, when you advertise a rental property, you must display the “total price” clearly and conspicuously. This total price must include all mandatory fees that a tenant cannot reasonably avoid, and importantly, the total price must be displayed more prominently than any other pricing information.

The total price must include base rent plus any fee that all or most tenants must pay, such as trash removal fees, included utility fees, pest control fees, administrative fees, and pet fees. Excluded from the total advertised price are governmental fees or taxes and utility costs when the tenant is individually metered. The total price also need not include fees that are “reasonably avoidable” by the tenant. A “reasonably avoidable” fee is a fee that is optional. For example, if a tenant may pay an additional fee for garage parking but is not required to do so and other off- or on- street parking is available, then such a fee is reasonably avoidable and need not be included in the advertised total price.

Specific Restrictions on Fees Landlords May Charge

Beyond the advertising and disclosure requirements, Colorado law now prohibits or caps several types of fees commonly charged by landlords. C.R.S. § 6-1-737 prohibits fees for services the landlord doesn't actually provide and prohibits rent payment processing fees unless the tenant has at least one fee-free payment method available. The statute also prohibits charging late fees on anything other than rent itself.

Additionally, C.R.S. § 38-12-801(3)(a)(VI) caps markups on third-party costs that are passed through to tenants. If you're billing tenants for services provided by a third party—such as water billing services, valet trash, or similar amenities—any markup you charge is limited to either $10 per month or 2% of the underlying cost. You cannot charge both.

Special Considerations for Utility Billing

The statute contains detailed provisions about utility billing that warrant particular attention. Landlords generally cannot require tenants to pay for utilities above the amount charged by the service provider to the tenant's unit, except for the limited administrative fee discussed above (either $10 per month or 2% of the bill, but not both). However, if you use submetering to bill tenants for their actual individual usage, those variable utility charges are excluded from the “total price” disclosure requirement.

Many Colorado properties use master meters and Ratio Utility Billing Systems (RUBS) to allocate utility costs among tenants. In November 2025, the Colorado Attorney General issued guidance indicating that enforcement would be flexible for existing properties using master meters, recognizing that requiring individual meters could impose prohibitive retrofit costs. The AG's guidance acknowledged “significant uncertainty” in the statute's application to these systems and noted that penalizing properties using master meters would be “contrary to the intent of HB 25-1090.” The AG also indicated that a legislative fix is expected during the 2026 session. Landlords using RUBS or master meter systems should monitor developments closely as the legislature considers clarifying amendments.

Consequences of Non-Compliance

Violations of C.R.S. § 6-1-737 are considered deceptive, unfair, and unconscionable trade practices under the Colorado Consumer Protection Act. The remedies available to tenants are significant and should not be underestimated.

Tenants can send a written demand for reimbursement of unlawfully charged fees, for actual damages, and demanding that you cease the violating practice. If you don't comply within 14 days of receiving such a demand, you become liable for actual damages plus 18% interest, compounded annually. Tenants may also refuse to pay prohibited fees and notify you of their refusal. Any lease provision that violates the statute is void. Additionally, the Colorado Attorney General has enforcement authority and can bring actions against landlords who violate the law.

What steps should landlords take now?

C.R.S. § 6-1-737 represents a significant shift in how Colorado landlords must structure and communicate their pricing. The law is new, and we can expect additional guidance, potential legislative amendments, and likely litigation that will clarify ambiguous provisions over the coming months and years. There are a few steps you, your management company or your attorney should take immediately to be sure you are in compliance:

First, review all lease agreements and identify every fee you charge. Determine which fees must be included in advertised rent and which fees may need to be eliminated or restructured. Remember that lease provisions violating this statute are void and unenforceable.

Second, update all advertising immediately. Every rental listing, whether on your website, Zillow, Craigslist, a newspaper, bulletin board or on paper flyers must show the total price prominently. Eliminate language like “Rent: $1,500 + fees” or “Starting at $1,200.” The headline number must be the actual total amount a typical tenant will pay.

Third, if you're billing for utilities, confirm your billing method and ensure compliance. If you're using submetering, document that tenants are being charged based on actual individual usage. If you're using RUBS or a master meter system, review the AG's guidance carefully and consider whether clarifying amendments from the 2026 legislative session may affect your practices.

Marketing materials and lease documents must be consistent with the new law across your entire operation. For many landlords, the compliance burden is real. Fee structures that were standard practice in 2025 may now create substantial legal exposure. The upfront work required to ensure compliance—reviewing leases, updating advertising, restructuring fees, and training staff—is considerable but necessary.

If you're uncertain about whether your current practices comply with C.R.S. § 6-1-737, or if you need assistance restructuring your leases and fee schedules, Coakley Law can help. Our firm works extensively with Colorado landlords and understands both the practical realities of property management and the legal requirements you must navigate.

THIS IS NOT LEGAL ADVICE.  This blog post provides general information about C.R.S. § 6-1-737 and does not constitute legal advice. The application of this statute to specific situations depends on individual facts and circumstances. Landlords should consult with qualified legal counsel regarding their particular compliance obligations.