Colorado Rental Junk Fee Ban: All-In Price Law 2026

The law defines total price as the maximum total of all amounts, including fees and charges, that a person must pay to purchase, enjoy, or utilize the rental, or that aren't reasonably avoidable. That single figure has to be disclosed clearly and conspicuously, and displayed more prominently than any other pricing information on the page or in the lease materials. A landlord can't satisfy this by listing rent prominently and burying mandatory fees in smaller text elsewhere.

[Cite: HB25-1090, adding Colorado Revised Statutes section 6-1-737]

In practice, an apartment advertised at $1,200 with a mandatory $50 trash fee has to show $1,250 as the price a prospective tenant sees, not $1,200 with the trash fee disclosed separately or later in the process.

Colorado Revised Statutes section 6-1-737(4) prohibits a landlord from charging: utility-related fees exceeding what the utility provider actually charges; fees that increase more than 2% annually, other than utilities; property tax-related charges passed through as a separate fee; payment processing fees when no cost-free payment method is offered; late fees on amounts other than rent itself; charges for maintenance the landlord is already legally required to provide as part of habitability; any amount exceeding the total price actually disclosed; fees for services that weren't actually provided; and common area maintenance charges.

[Cite: HB25-1090, adding Colorado Revised Statutes section 6-1-737(4)]

That's a specific, enumerated list rather than a general prohibition on fees. A landlord auditing existing lease and fee structures against this law needs to check each fee type against this list individually, since a fee not named on it isn't automatically banned just because it's a fee.

Two categories are specifically carved out from the total price requirement. Government charges and taxes can be shown separately rather than folded into the advertised total. Utility provider costs are also exempted under section 6-1-737(2)(d), meaning a landlord can bill actual utility costs separately from the total price, as long as they're properly disclosed.

[Cite: HB25-1090, amending Colorado Revised Statutes section 6-1-737(2)(d)]

This distinction matters for how a lease or listing is structured. The total price has to reflect the mandatory rent and fee amount a tenant can't avoid; utilities and taxes, which vary and are tied to actual usage or government-set rates, sit outside that figure.

Where a landlord charges a utility administrative fee, on top of passing through actual utility costs, that fee is capped at $10 a month or 2% of the bill, whichever applies, and not both stacked together. This lines up with the ratio utility billing guardrails Colorado adopted separately around the same period, and reflects the same underlying concern: a landlord shouldn't be able to turn a utility pass-through into a profit center through an uncapped administrative markup.

[Cite: HB25-1090, amending Colorado Revised Statutes section 6-1-737]

A tenant, or anyone aggrieved by a violation, can send a landlord a written demand for reimbursement without needing to file a lawsuit first. If the landlord doesn't comply within 14 days, they're on the hook for actual damages plus 18% annual interest, compounded annually.

[Cite: HB25-1090, adding Colorado Revised Statutes section 6-1-737]

Beyond the individual demand process, this is enforceable as a deceptive trade practice under Colorado's existing consumer protection framework, which gives the Attorney General a separate enforcement path involving injunctive relief and civil penalties, on top of whatever a tenant pursues directly.

The Colorado Attorney General issued guidance clarifying that this law applies prospectively. Enforcement covers leases executed, amended, or renewed on or after January 1, 2026, not existing leases that haven't been touched since before that date. A landlord doesn't need to retroactively restructure a lease that was already in place and hasn't come up for renewal.

[Cite: Colorado Attorney General guidance on HB25-1090]

For landlords using ratio utility billing (RUBS), where utility costs are allocated across tenants by formula rather than individual metering, the Attorney General's guidance sets out four specific conditions under which enforcement won't be targeted at that practice: no overbilling occurs, any administrative fee stays within the statutory cap described above, common area costs are excluded from what's allocated to tenants, and the allocation method is clearly disclosed.

[Cite: Colorado Attorney General guidance on HB25-1090]

A property manager already using RUBS should check current practice against these four conditions specifically, since this guidance functions as the practical compliance bar for that billing method under the new total-price framework, even though RUBS itself was addressed more directly in a separate Colorado law.

Colorado's ratio utility billing rules, adopted separately, already required the aggregate amount billed to tenants not exceed the property's actual utility bill, no markup or added fee, exclusion of common-area costs, and lease disclosure of the allocation method. HB25-1090's total-price requirement and its own utility fee cap sit on top of that existing framework rather than replacing it. A landlord using RUBS needs to satisfy both sets of requirements together, not treat compliance with one as automatically satisfying the other.

[Cite: HB25-1090, amending Colorado Revised Statutes section 6-1-737]

The practical starting point is pulling every fee currently charged, whether disclosed at signing, billed monthly, or assessed at move-out, and checking each one against the specific banned-fee list in section 6-1-737(4). A fee that survives that check still needs to be folded into the advertised total price unless it falls into the government-charges or utility-cost exceptions. Advertising and leasing materials, including websites and any third-party listing platforms, need the same single, prominent total-price treatment rather than a base rent figure with fees disclosed elsewhere in the process.