Starting January 1, 2026, all Colorado businesses will need to update how they list, advertise, and set their prices. The new Deceptive Pricing Practices Law, known as House Bill 25-1090, is one of the most comprehensive consumer protection laws the state has enacted. It focuses on hidden fees, confusing service charges, and unclear pricing.
If you own property, manage rentals, or run a service-based business, this law impacts you.
What the Law Does
Colorado lawmakers enacted House Bill 25-1090 to ban “drip pricing,” where a price appears lower than it actually is until mandatory fees are added at checkout or signing. The law now requires that every good, service, or property offered for sale displays a single total price that includes all mandatory fees.
That total must be clear, easy to understand, and visible before a customer agrees to buy. The rule applies to everything from apartment leases to restaurant menus and online checkout screens.
Violations are considered deceptive trade practices under the Colorado Consumer Protection Act. This means noncompliance isn’t merely a technical error; it’s a legal offense with significant financial penalties.
Penalties with Real Consequences
Businesses that do not comply may be required to refund every illegally charged fee. If they refuse, the law imposes an 18 percent annual interest penalty compounded each year until payment is made.
Because violations fall under the Consumer Protection Act, the Attorney General can investigate and impose civil penalties. Customers and tenants can also file private lawsuits to recover damages and attorney fees. There is no requirement for warning or pre-suit notice. One complaint can proceed directly to court.
For landlords and businesses with recurring fees, the potential liability accumulates quickly. A $25 monthly “processing” charge to 40 tenants could result in $12,000 in refunds, plus years of accrued interest.
Part One – Real Estate and Property Owners
The new law introduces significant changes in how landlords and property managers advertise and set rent. All offers or listings must show a single total price for the dwelling, including all mandatory fees and charges except for actual utility costs billed directly by the provider.
The law prohibits:
- Markup charges on utilities above the actual cost, except for a cap of two percent or ten dollars per month.
- Add-on fees such as “maintenance,” “processing,” or “administrative” that are unrelated to rent.
- Passing property tax or payment processing costs to tenants if a free payment option isn’t available.
- Fees for services the landlord is already responsible for providing, such as maintaining habitability.
- Charges for services or products not delivered.
Every violation may result in refund duties and penalties. Lease clauses that breach these rules are invalid under Colorado law.
What to do now
Landlords should review all leases, payment portals, and marketing materials before January 2026. Combine mandatory fees with a single advertised price. Remove add-ons that cannot be justified. Offer at least one free payment option. And document every update in writing.
Part Two – Service-Based Businesses
Restaurants, delivery companies, gyms, salons, and other service providers must also comply. The new law requires them to display the total price for any service or product before the customer agrees to purchase.
Restaurants must disclose any mandatory service charge, including its percentage or amount, and explain how it is divided between staff and management. Delivery apps are required to display all flat fees and variable fees when a customer selects an order. Gyms and subscription services must include facility fees or membership charges in the total price shown to customers.
Online or app-based offers must ensure these disclosures are unavoidable. If an ad is shown in multiple languages, each disclosure must be present in every language used.
Failing to meet these standards is considered a deceptive or unfair act. Each affected customer can request repayment of all illegal charges plus 18 percent annual interest. One mistake can lead to a class action.
Part Three – Professional Services and Variable Pricing
Some services, like legal work, cannot be accurately predicted in total cost beforehand. The legislature acknowledged this and established an exemption for services where the overall price depends on time, distance, or client decisions.
Lawyers, accountants, and consultants are included in this section. They stay compliant if they clearly explain:
- The factors that determine the total cost, such as hourly rates or the scope of work.
- Any required administrative or processing fees.
- The total price may fluctuate depending on those factors.
This means law firms are not required to list a single total price, but they must disclose how the fee will be calculated and if it could change.
Example of compliance
Our hourly rates range from $250 to $400 depending on the attorney’s experience. You will be billed for the actual time spent on your matter. Since the total hours required depend on the complexity of your case, the total cost cannot be determined in advance. We do not charge any additional administrative or processing fees.
That disclosure meets the new law’s transparency requirement.
For flat-fee work, the total advertised price must include all mandatory charges. A $995 price plus an extra $100 “document fee” is no longer compliant. The correct total price to display is $1,095.
Any service advertised online must clearly display these disclosures. The information should be easy to read and obvious, not hidden in fine print or behind a link.
Professionals who conceal fees or fail to clarify how pricing is determined risk being labeled as deceptive under the Consumer Protection Act. That could result in refund obligations, 18 percent annual interest, and potential civil enforcement.
What Businesses Should Do Now
The law goes into effect on January 1, 2026. The upcoming months are the time to prepare.
Step 1 – Audit your pricing
Review leases, contracts, invoices, and online checkout pages. Every offer should display the total price and clearly explain how it is calculated.
Step 2 – Update your agreements
Revise rental agreements, service contracts, and engagement letters. Remove or rewrite any clause that introduces unclear fees.
Step 3 – Review online systems
Ensure your website or app clearly shows total prices upfront and that disclosures are simple to see and understand.
Step 4 – Train your team
Anyone quoting prices to clients or tenants needs to understand the new rules.
Step 5 – Keep documentation
Keep dated copies of revised forms and screenshots of pricing displays to demonstrate good-faith compliance if questions come up.
The Bigger Picture
This law goes beyond just compliance. It aims to rebuild trust between businesses and the people they serve. Colorado clearly shows that transparency is now the standard. Businesses that keep pricing simple and honest will avoid penalties and strengthen their relationships with customers and clients.
How Miller & Steiert Can Help
For over sixty years, Miller & Steiert has advised Colorado property owners, businesses, and professionals on new regulations and legal changes. We assist clients in identifying risks, rewriting contracts, and developing lasting compliance systems.
If you manage rentals, run a business, or offer professional services, now is the time to get ready for Colorado’s new Deceptive Pricing Practices Law. Our team can review your leases, pricing strategies, and agreements to ensure you stay compliant before the law comes into effect.
Contact Miller & Steiert today to arrange a compliance review and safeguard your business before January 2026.
