Every price you advertise — on your website, your menu, your storefront window, your checkout page — must now show the full amount a customer could pay, upfront, before they decide to buy. Not the base price with fees revealed three clicks later. The total.
That is the core of Colorado's "Protections Against Deceptive Pricing Practices" law, House Bill 25-1090, which took effect January 1, 2026. If you sell goods, services, or property to Colorado customers, this law covers you — not just landlords and restaurants, even though those two industries got most of the headlines. And enforcement is already underway: the state attorney general's office confirmed it began receiving junk-fee complaints as soon as the law went live.
This guide explains what the law requires, which businesses get special rules or exemptions, what noncompliance can cost you, and the practical steps to get your pricing displays compliant.
What the Law Actually Requires
HB25-1090 does not ban fees. You can still charge service fees, amenity fees, convenience fees, and surcharges. What you cannot do is advertise a price that hides them.
The central requirement is the total price disclosure: whenever you offer, display, or advertise pricing information for a good, service, or property, you must clearly and conspicuously disclose the maximum total of all amounts a person may pay — including every mandatory fee and charge.
Three related rules come with it:
- No misrepresentation. You may not misrepresent the nature and purpose of any pricing information — for example, labeling a mandatory surcharge as if it were a government tax.
- Explain what is not in the total. For any pricing component that sits outside the total price, you must clearly and conspicuously disclose its nature and purpose.
- Prominence matters. The total price must be displayed more prominently than any other pricing information. A large "$49" with a tiny "+ $18 in fees" underneath is exactly the pattern the law targets.
What stays out of the total
Not everything goes into the all-in number. The law expressly excludes:
- Government charges — sales tax and other taxes or government-imposed fees need not be included (though you may voluntarily include them).
- Shipping charges — likewise excludable unless you choose to include them.
- Truly optional fees — charges the customer can decline should not be part of the total price.
But "optional" means genuinely optional. A fee the customer cannot realistically avoid — a mandatory service charge added to every check, a "required" amenity fee on every lease — belongs in the total. When in doubt, ask whether the customer can complete the transaction without paying it. If not, disclose it upfront.
Who Is Covered: Every Business, Not Just Landlords
Early coverage framed HB25-1090 as a rental-housing and restaurant bill, because those industries fought hardest over it and got industry-specific provisions. Do not let that framing mislead you. The total-price disclosure requirement applies to any person offering, displaying, or advertising pricing for a good, service, or property in Colorado.
That means retail shops, e-commerce sellers, ticket sellers, hotels and vacation rentals, salons, repair shops, gyms, subscription services, contractors, and professional service firms are all in scope. If a Colorado consumer sees your price before buying, the law has something to say about how you present it.
Restaurants and bars: the service-charge rule
Food and beverage establishments get a specific compliance path: you satisfy the law if your total price disclosure includes the amount of any mandatory service charge and how that charge is distributed — for example, how much goes to kitchen staff versus the house.
This is why "kitchen appreciation" and similar line items did not disappear on January 1. They are legal, but they must be disclosed before the customer orders — on the menu, on a sign by the register, in a banner on the ordering page, printed on the receipt, and even explained audibly to phone customers. The disclosure also has to be easy to understand, not buried in fine print.
Landlords: the strictest section
Rental housing carries the heaviest obligations. Landlords and their agents must advertise one total monthly price that includes all mandatory fees — pet rent, valet trash, smart-home fees, package handling, amenity fees, and the like. The only carve-out is utilities: landlords are not required to include the actual amount charged for utility services provided to the dwelling unit.
The law goes further for rentals than for any other industry: it outright prohibits landlords from requiring tenants to pay certain fees and from including provisions in a written rental agreement that impose a prohibited fee. And it creates a private fast-track remedy — an aggrieved person can send a written demand for reimbursement of an unlawfully imposed fee (or to refuse to pay one), and if the landlord does not make full payment or stop the charge within 14 days, liability jumps to actual damages plus 18% interest, compounded annually.
The backdrop here is hard to miss: state and federal enforcers had just finished a case against a national property-management company accused of hiding hundreds of dollars in monthly fees — package handling, utilities, smart-home service, valet trash — behind advertised rents. That case ended with the company agreeing to stop misrepresenting prices and paying a $24 million penalty. HB25-1090 writes the lesson of that case into statute for every landlord in the state.
Service providers whose total price is genuinely unknowable
The original bill would have forced every business to state a maximum total price upfront — a serious problem for accountants, lawyers, consultants, contractors, and anyone whose final price depends on scope discovered along the way. After industry advocacy, the final law includes a workable alternative: if you can demonstrate that your total price is indeterminate at the time of the offer, you comply by clearly and conspicuously disclosing:
- The factors that determine the total price (hourly rates, timelines, deliverables, scope assumptions),
- Any mandatory fees associated with the transaction, and
- A clear statement that the total price may vary.
For firms, that translates into three concrete updates: rewrite proposal and engagement-letter templates to spell out pricing factors and add an explicit may-vary disclaimer, audit every place you advertise prices (website, directories, marketing emails) for the same disclosures, and train everyone who prepares quotes. Fixed-fee shops can simplify compliance by bundling multiple fees into one quoted price; hourly shops should keep rates explicit and state their scope assumptions in writing.
Other exemptions and special cases
- Delivery network companies comply through a tailored disclosure: state clearly and conspicuously that an additional flat, variable, or percentage fee is charged, disclose mandatory fees, and note the total may vary.
- Broadband, cable, and satellite providers that comply with applicable federal pricing-transparency rules are covered by that compliance.
- Real estate settlement services — additional fees tied to settlement are permitted so long as they are not broker commissions or fees.
- Federally governed transactions — if you can demonstrate compliance with an applicable federal pricing-transparency rule for the transaction, or that federal law preempts state law, the state act does not add a second layer.
What Noncompliance Can Cost
A violation of HB25-1090 is classified as a deceptive, unfair, and unconscionable act or practice under the Colorado Consumer Protection Act (CCPA) — which unlocks the CCPA's full enforcement machinery:
- Attorney General enforcement. The AG (or a district attorney) can seek civil penalties of up to $20,000 per violation, and each affected consumer or transaction counts as a separate violation. A noncompliant price displayed to hundreds of customers is not one $20,000 exposure — it is hundreds of them.
- Private lawsuits. In a private civil action, a business found to have engaged in a deceptive trade practice is liable for the greater of actual damages, $500, or treble (triple) damages — plus attorney fees and costs, which is what makes small-dollar fee cases worth filing.
- The rental fast track. For property disputes, the written-demand procedure with 18% compounded interest means ignoring a tenant's complaint letter is the most expensive possible response.
The AG's office has rulemaking authority to implement the act, and while no additional guidance had been issued as of early 2026, the complaint intake at the AG's consumer protection division is already active. Assume your competitors' customers — and yours — know where to file.
Your Compliance Checklist
Work through this list in order. Most small businesses can complete it in a week.
1. Inventory every place you show a price
Walk through your business as a customer would: website (including mobile view), online checkout flow, third-party marketplaces and booking platforms, printed menus and price sheets, in-store signage, contracts and order forms, social media ads, and email promotions. Screenshot each one. You are looking for any price that omits a mandatory fee the customer will actually pay.
2. Decide fee by fee: bundle it, disclose it, or drop it
For each fee you charge, make a deliberate choice:
- Bundle it into the advertised price. Simplest compliance and often better marketing — "$85 all-in" beats "$69 plus fees" once every competitor must show totals too.
- Disclose it clearly and conspicuously alongside the total, with its nature and purpose explained. Required for anything mandatory that stays separate.
- Drop it if it cannot survive sunlight. The Denver renter whose landlord itemized a $175 "amenity fee" as $100 for a loft, $50 for a mountain view, and $25 for vinyl flooring is a cautionary tale: disclosure does not legitimize a charge customers experience as fabricated.
3. Fix prominence, not just presence
Adding the total in small gray text while the base price stays big and bold does not comply. The total must be the most prominent price on the page, menu, or sign. Check especially: search-result snippets, category pages that show "from $X" pricing, and multi-step checkouts where fees appear only at the final step.
4. Rewrite quotes, proposals, and engagement letters
If your final price legitimately varies, your documents must say so properly: list pricing factors, name mandatory fees, and state plainly that the total may vary. Have legal counsel or your professional liability carrier review the new template before it goes out — these documents are both your compliance evidence and your client contract.
5. Train everyone who quotes prices
The person answering the phone, the tech writing the estimate, the leasing agent giving the tour — anyone who states a price to a customer needs to state the compliant one. A perfect website undone by verbal quotes is still a violation.
6. Track fees separately in your books
Here the compliance exercise pays for itself. Every mandatory fee you disclose should map to its own line item or sub-account in your books — service charges, processing fees, amenity fees, delivery fees. Separate tracking lets you prove what you disclosed, reconcile fee income at tax time, and spot immediately when a "small" fee has grown into a material share of revenue. If your current setup buries all fees in one miscellaneous income account, this law is your reason to fix that now.
How Colorado Fits the National Patchwork
Colorado is not acting alone, which matters if you sell across state lines:
- California's SB 478 has required all-in pricing since mid-2024, with restaurants initially carved out and then pulled back in.
- The FTC's Rule on Unfair or Deceptive Fees has required total-price disclosure for hotels, vacation rentals, and live-event ticketing nationwide since May 2025.
- Connecticut, Massachusetts, Minnesota, and Nevada are among the states with parallel disclosure laws already in effect.
- Colorado's own HB24-1378 already forced ticket sellers to show the total ticket price (delivery fees and sales tax excepted) before purchase, with penalties up to $20,000 per violation.
The practical upshot: if you already rebuilt your pricing displays for California or the FTC rule, extending the same treatment to Colorado transactions is mostly an exercise in consistency. If you have not complied anywhere yet, build once to the strictest standard you face — Colorado's "maximum total, most prominent price" test is among the strictest — and apply it everywhere.
Keep Your Pricing (and Your Books) Transparent
HB25-1090 rewards the businesses that were already honest about their prices: when everyone must show the total, the shop with genuinely lower all-in pricing finally wins the comparison. Treat compliance as a pricing-strategy review, not just a legal chore — bundle what you can, disclose what you must, and cut what you cannot defend.
And since every disclosed fee now needs to be tracked, reconciled, and reported accurately, make sure your books are up to the task. Beancount.io offers plain-text accounting that gives you complete transparency and control over your financial data — every fee mapped to its own account, every change version-controlled. Get started for free and keep your financial records as clear as your prices now have to be.
