Other | Colorado Concealed Carry

Colorado SB25-003: Buying a Semiautomatic Firearm On or After August 1, 2026

The Headline

Since August 1, 2026, you cannot buy a "specified semiautomatic firearm" in Colorado until you have done two things in order: gotten a firearms safety course eligibility card from your county sheriff, then passed a Colorado Parks and Wildlife certified firearms safety course. The requirement is now in force. This is C.R.S. 18-12-116, added by Senate Bill 25-003 (2025 Regular Session, ch. 68), which Governor Polis signed on April 10, 2025.

Two things this law does not do. It does not touch firearms you already own. And it is not a concealed carry rule. Your Colorado concealed handgun permit does nothing for you here, and the background check and training you did for your permit do not carry over. CPW is explicit: "All background checks and courses taken for a concealed carry weapon (CCW) are not reciprocal for the Firearms Safety Program."

The card is good for 5 years. The course completion is good for 5 years. The CPW record fee is $52, your sheriff can add a processing fee of their own, and your instructor can charge for the class.

What Counts as a "Specified Semiautomatic Firearm"

C.R.S. 18-12-116(1)(d)(I) defines a specified semiautomatic firearm (the state and the industry both abbreviate it SSF) as either:

• A semiautomatic rifle or semiautomatic shotgun with a detachable magazine, or
• A gas-operated semiautomatic handgun with a detachable magazine.

"Detachable magazine" under 18-12-116(1)(b) means a feeding device that is not permanently attached and can be removed without rendering the firearm incapable of accepting any magazine. An attached tubular magazine under the barrel is not a detachable magazine.

"Gas-operated semiautomatic handgun" under 18-12-116(1)(c) means a semiautomatic handgun that traps or harnesses part of the high-pressure gas from a fired cartridge to cycle the action, through a long-stroke piston system, a short-stroke piston system, a direct impingement system that strikes the bolt, bolt carrier, or slide assembly, a hybrid of those, or a blowback-operated system that uses the expanding propellant gasses acting on the cartridge case to drive the breechblock or breech bolt rearward.

What is excluded

C.R.S. 18-12-116(1)(d)(II) carves seven categories out of the definition:

1. A firearm designed to accept, and capable of operating only with, .22 or lower caliber rimfire ammunition, unless the firearm has a separate upper and lower receiver.
2. A firearm manually operated by bolt, pump, lever, or slide action.
3. A firearm with a permanently fixed magazine that cannot accept more than fifteen rounds, including a semiautomatic firearm that has been converted to a permanently fixed magazine under that capacity.
4. A single or double action semiautomatic handgun that uses recoil to cycle the action.
5. Thirty-five named models, as they existed and were configured on April 10, 2025: AG42 Ljungman, Benelli Argo E Pro, Benelli R1 Big-Game Rifle, Browning BAR MK 3, Browning BAR LongTrac Rifle, Browning BAR ShortTrac Rifle, FN Model 49, Fusil Automatique Modele 1917 (RSC M1917), Gewehr 43, Globco Mohawk, Hakim Rifle, HK SL6, HK SL7, M1 Carbine, M1941 Johnson Rifle, Marlin Camp Carbine, MAS49, Remington Model 4, Remington Model 8, Remington Model 740, Remington Model 742, Remington Model 750, Remington 7400, Ruger Deerfield Carbine, Ruger Mini-14 Ranch Rifle, Ruger Mini Thirty Rifle, Ruger Model 44, Springfield Armory M1A Standard Issue Rifle, SVT 40, Valmet Hunter M88, VZ.52, Winchester Model 100, Winchester Model 1905, Winchester Model 1907, and Winchester Model 1910.
6. A firearm that has been made permanently inoperable.
7. An antique firearm as defined in 18 U.S.C. 921(a)(16), or a curio or relic as defined in 27 CFR 478.11.

How to check a specific model

Do not guess from the statutory text. SB25-003 directed the Colorado Department of Revenue division that issues state firearms dealer permits to publish model-specific guidance, and the Firearms Dealer Division (FDD) does that. The current Specified Semiautomatic Firearms Guidance at sbg.colorado.gov is dated July 30, 2026. The list has moved twice: in its July 1, 2026 letter to industry, the FDD said it collected feedback for six weeks, reviewed 183 responses, and removed 32 firearms from its initial draft list; then on July 30, 2026 it updated the guidance again based on public feedback, adding thirteen firearms on page 144. If you checked a model against the July 1 version, check it again.

The FDD warns that the list "is not all-inclusive of firearms currently available, or that will be available in the future" and that it is reviewed on an ongoing basis as new firearms are manufactured. If your firearm is not on the list and you need an answer, you can petition the Firearms Dealer Division for a statement of position.

One more FDD rule to know about: weapons parts kits. In Bulletin 26-03, dated July 29, 2026, the FDD takes the position that a weapons parts kit is a "firearm" under C.R.S. 18-12-101(1)(j), applying the eight-factor "readily" test from 27 CFR 478.11 and citing Bondi v. VanDerStok, 604 U.S. 458 (2025). If the completed kit would meet the specified semiautomatic firearm criteria, all of C.R.S. 18-12-116 applies to the kit itself, card and course included.

Firearms You Already Own Are Not Affected

C.R.S. 18-12-116(2) reaches five verbs: manufacture, distribute, transfer, sell, and purchase. Possession is not one of them. There is no registration requirement, no surrender requirement, and no grandfather paperwork for an SSF you already own. CPW puts it plainly: "This law only affects those who will purchase and/or transfer SSFs on or after August 1, 2026."

Carry, transport, and storage rules are unchanged by SB25-003. Those still come from C.R.S. 18-12-105, 18-12-105.6, 18-12-114, and 18-12-114.5.

The Purchase Path, Step by Step

CPW runs this through an online Firearms Safety System (FSS) at coloradofss.com. The five steps, per CPW's published customer journey:

1. Apply. Create an account at coloradofss.com and submit an application. It goes into your county sheriff's queue. If you have hunter education, you add that information here.
2. Take your documents to the sheriff. You must provide a name-based background check and a government-issued photo ID. Fees are collected at this step. The CPW portion is $52.00, and each sheriff sets their own fee on top of that.
3. Sheriff review and card issuance. The sheriff reviews the documents, determines eligibility, issues the eligibility card, and enters the card into the FSS. You get an automated email either way. If you are denied, your local sheriff's office contacts you.
4. Course and exam. Find a verified Firearms Safety Program instructor and enroll. The instructor checks the FSS to confirm whether you qualify for the Basic (4 hour) or Extended (12 hour) course. You must pass the exam and the hands-on practical with 90% or better. You get an email as soon as the instructor enters pass or fail. If you pass, you have 5 years to buy an SSF.
5. Purchase. The dealer confirms your eligibility in the FSS and runs the purchase.

You can take the course anywhere in Colorado from any verified Firearms Safety Program instructor. For the card, C.R.S. 18-12-116(5)(b)(II) says only that an applicant submits the application "to the sheriff" and does not impose a county-of-residence requirement, but practice varies by county: each sheriff sets their own processing fee, and CPW warns that some counties are not accepting applications at all. Call the sheriff's office you plan to use before you apply.

The Eligibility Card

Statutory authority is C.R.S. 18-12-116(5)(b). Every sheriff shall issue these cards. Key rules:

• Validity: 5 years from the date of issuance.
• Application contents: your full name and date of birth, on a form created by CPW, plus three attestations: that you have no state or federal conviction that would prohibit you from purchasing or possessing a firearm; that you will not violate state law on the purchase, possession, storage, and lawful use of firearms; and that you will only transfer a firearm under C.R.S. 18-12-112 and 18-12-116 and will not give a person you believe would be a danger to themself or others access to a firearm in your possession.
• Documents: government-issued photographic identification, plus the results of a completed name-based background check of national and Colorado public criminal history and judicial databases performed by a third-party vendor that does those checks as a normal part of its business, plus an attestation from the vendor that it performed the check.
• Fees: the card fee is the sheriff's processing fee plus the firearms training and safety course record fee set under C.R.S. 33-9-115(5)(a). Each sheriff may set a processing fee that reflects the sheriff's actual direct and indirect costs. The sheriff remits the record fee to CPW. The fee is not refunded if the sheriff denies your application. CPW's fee schedule lists the record fee at $52 and the sheriff's office fee as varying by county, and states you are charged whether or not your application is approved. The Parks and Wildlife Commission may adjust the record fee, but not more than once per year.
• Mandatory denial: the sheriff shall deny if you cannot lawfully possess a firearm under state or federal law, or if the sheriff cannot positively identify you.
• Discretionary denial: the sheriff may deny if the sheriff has a reasonable belief that documented previous behavior by you makes it likely you will present a danger to yourself or others while holding a card.
• Revocation: the sheriff shall revoke if the sheriff knows the holder cannot lawfully possess a firearm, and may revoke on the same documented-previous-behavior standard.
• What the card shows: your full name, the county of issuance, the signature of the issuing sheriff, and the issuance and expiration dates.
• Lying on the application is perjury in the second degree under C.R.S. 18-8-503, and a conviction requires the sheriff to revoke a card already issued.
• Appeals: a denial or revocation must be in writing, must state the grounds, and must inform you of your right to judicial review. Review runs under Rule 106(a)(4) and (b) of the Colorado Rules of Civil Procedure. The sheriff carries the burden: preponderance of the evidence for ordinary ineligibility, and clear and convincing evidence when the denial or revocation rests on the danger finding. The court may award attorney fees to the prevailing party.
• Sheriffs are not liable for damages resulting from good-faith compliance with the card provisions.

The Two Course Tiers

Both tiers are set by C.R.S. 18-12-116(5)(a). You must already hold a valid eligibility card to enroll, and the instructor has to verify that in the state record system before letting you attend.

Three statutory qualifying pathways sit in C.R.S. 18-12-116(3)(e)(I). You may buy an SSF if you:

• (A) completed a CPW-certified hunter education course and completed a basic firearms safety course within the 5 years before the purchase; or
• (B) completed an extended firearms safety course within the 5 years before the purchase; or
• (C) completed an extended firearms safety course more than 5 years before the purchase and completed a basic firearms safety course within the 5 years before the purchase.

Hunter education by itself does not qualify you to buy. CPW is direct about this: "Completion of a hunter education course certified by CPW will not qualify you for purchasing a SSF." You still need the Basic course on top of it. If your hunter education came from another state, it has to be CPW-certified, and you must bring your hunter education card or record to a CPW office to get it verified in CPW's records system.

No other firearms safety course counts. Not an NRA course, not a state concealed carry class, not a hunter safety course from a private provider.

When the 5 years runs out, you start over at Step 1.

What gets taught

C.R.S. 18-12-116(5)(a)(IV) requires both tiers to satisfy CPW's adopted course requirements and to include, at minimum, instruction on:

• Safe handling of semiautomatic firearms and ammunition magazines
• Safe storage of firearms and child safety
• Firearm deaths associated with mental illness
• Extreme risk protection orders under Article 14.5 of Title 13, C.R.S.
• Victim awareness and empathy

The exam

C.R.S. 18-12-116(5)(a)(V) requires the instructor to give an exam at the end of the course that tests knowledge of the subjects taught and requires the student to demonstrate the ability to safely handle firearms and a mastery of gun safety. The statute sets the passing score for the basic course at at least ninety percent. CPW's published guidance applies the same 90% minimum to the extended course and describes the requirement as passing both a written exam and a hands-on practical at 90% or better.

The instructor has 3 business days after completion to report the result into the state record system created by C.R.S. 33-9-115.

For Instructors: How to Get Approved to Teach

You need two credentials, in this order.

First, sheriff verification under C.R.S. 18-12-202.7. This is the same verified-firearms-instructor status Colorado created for concealed handgun training in HB 24-1174 (effective August 7, 2024). To get it you must:

• Hold a valid Colorado permit to carry a concealed handgun issued under Part 2 of Article 12, and not a temporary emergency permit under C.R.S. 18-12-209; and
• Be certified as a firearms instructor by a federal, state, county, or municipal law enforcement agency, a college or university, a nationally recognized organization that customarily offers firearms training, or a firearms training school, where that entity has instructors certified by a nationally recognized organization that customarily offers firearms training.

You apply to the sheriff of the county that is your principal place to conduct firearms training. Verification runs 10 years and can be renewed any time before it expires. The sheriff issues evidence of verification showing the expiration date, keeps a record of verified instructors, and must post the list on the sheriff's website with expiration dates. The sheriff may charge a fee covering actual direct and indirect costs. A sheriff shall revoke your verification if you stop meeting the requirements, and may revoke or suspend it if you teach a concealed handgun class or refresher that fails the Part 2 requirements and a training certificate still gets issued. After a suspension you can apply for reinstatement no earlier than 30 days out. Denials, suspensions, and revocations come with written notice and judicial review under C.R.S. 18-12-207.

Second, CPW's Firearms Safety Program Train the Trainer. CPW's training covers the curriculum, teaching and testing guidelines, and protocols, and walks you through the Firearms Safety System so you can create an account, register students, and enter course completion. The trainings are free, run virtually or in person, and are capped at 50 attendees per class, first come first served. CPW asks you to register for only one session. Sessions CPW has posted run 2 p.m. to 5 p.m. and are virtual: August 21, September 1, October 6, November 17, and December 2, 2026.

Once verified and trained, you appear on CPW's list of verified Firearms Safety Program instructors, and students statewide can take your class. Before class you must check the record system to confirm each student holds a valid eligibility card, and you must confirm which tier they qualify for.

Effective Dates and the Transition

The gap between April 10, 2025 and August 1, 2026 was deliberate. The definitions, the card scheme, the course rules, and the record system all had to exist before the prohibition could bite. The portal is live and the prohibition now applies.

One practical warning that still holds: as of August 11, 2026, CPW's program page still warns that some counties "are not accepting applications at all", so call your sheriff's office before you submit. County rollout has been uneven, so treat the card step as the one most likely to cost you time.

Purchases and Transfers Before and After August 1, 2026

• Completed before August 1, 2026. C.R.S. 18-12-116(2) applies only to conduct "on or after August 1, 2026." A purchase that closes before that date is not covered.
• On or after August 1, 2026. You need the card, then the course, then the FFL's FSS check. No card and no course means no purchase.
• Pawn redemptions and consignment returns. The Firearms Dealer Division addressed these in Bulletin 26-02, dated July 24, 2026. "Transfer" under C.R.S. 24-33.5-424(1)(d) expressly includes redemption of a pawned firearm by a person who is not an FFL, and the FDD reads the return of a consigned firearm to its consignor as a transfer too, because it is a delivery from the dealer to the consignor. The consequence: the C.R.S. 18-12-116(3)(e) training requirements apply to anyone redeeming a pawned SSF or taking back a consigned SSF on or after August 1, 2026, regardless of when the firearm was originally pawned or consigned. If you pawn or consign an SSF now and redeem it in August, you need the card and the course to get it back. The FDD asks pawnbrokers and consignment dealers to raise this with customers before writing the agreement.
• Out-of-state buyers and dealers. C.R.S. 18-12-116(2) has a standing carve-out: you may sell or transfer an SSF to an individual residing in another state, or to a federally licensed firearm dealer.

Who Is Exempt from the Prohibition

C.R.S. 18-12-116(3) exempts these from the purchase and transfer ban:

• Law enforcement agencies equipping their peace officers, and POST-certified peace officers described in C.R.S. 16-2.5-101 whose employing agency requires or permits them to carry an SSF on duty
• The Department of Corrections, prison wardens, jail keepers, and heads of other detention institutions, equipping staff for official duties
• Armored vehicle businesses, for authorized employees in the course and scope of their duties
• Instructors and students of accredited gunsmithing courses at state-authorized institutions of higher education or schools regulated by the Colorado Division of Private Occupational Schools, for instruction, manufacture, repair, or maintenance during the course
• Members of the U.S. armed services or reserves, or the Colorado National Guard, in the performance of official duties
• FFLs receiving an SSF for temporary storage or permanent disposal
• Gunsmiths receiving an SSF for maintenance, repair, or modification and returning it to the lawful owner, unless the gunsmith has reason to believe the owner is prohibited from possessing it
• Institutions of higher education and instructors operating an approved educational program, for use and storage at the program location
• Public historical societies, museums, and institutional collections open to the public, if the SSF is rendered permanently inoperable before the sale or transfer
• Forensic laboratories and their authorized agents or employees, for use exclusively in forensic analysis
• Transfers by operation of law, or because of a death where the transferor is an executor, administrator, or trustee of a trust created in a will
• Blank-firing SSFs handled through an FFL for use solely as a film prop under C.R.S. 24-48.5-114
• People who satisfy one of the three training pathways in 18-12-116(3)(e)(I)

Penalties

Three collateral consequences ride along, per the SB25-003 bill summary:

• The Department of Revenue shall revoke the state firearms dealer permit of a dealer who unlawfully manufactures, distributes, transfers, sells, or purchases an SSF.
• The Colorado Bureau of Investigation shall deny a firearm transfer to a person convicted of the misdemeanor version of the offense within the 5 years before the transfer.
• A person convicted of the felony version is prohibited from possessing a firearm and certain other weapons.

SB25-003 also reworked the dangerous weapon list. It defines "rapid-fire device" and classifies rapid-fire devices as dangerous weapons, and it repealed the definition of "machine gun conversion device" and removed those devices from the dangerous weapon list.

Pending Litigation: The Law Is In Effect

SB25-003 is being challenged in federal court, and no part of it has been enjoined. The law took effect August 1, 2026 and is fully enforceable unless and until a court says otherwise. In a joint filing on August 10, 2026, signed by counsel for both sides, the parties told the court that for the general public "the only way to purchase a specified semiautomatic firearm" is the permit-to-purchase scheme, which "went into effect on August 1, 2026."

The case is Del Toro v. Polis, No. 1:25-cv-02725 (D. Colo.), filed September 2, 2025. As captioned in that August 10, 2026 filing, plaintiffs are Israel Del Toro, Luke Sorensen, Nathanael Skiver, Jason Reeves, Garrett Flicker, and the Colorado State Shooting Association, the NRA's Colorado affiliate. Defendants are Governor Jared Polis, Attorney General Philip Weiser, District Attorney Michael J. Allen, and Laura Clellan. The claim is brought under 42 U.S.C. 1983 and is docketed as a civil rights action. Judge William J. Martinez presides, with Magistrate Judge Maritza Dominguez Braswell. Plaintiffs are represented by Mountain States Legal Foundation and, per the August 10, 2026 filing's signature block, First & Fourteenth PLLC, and argue the permit-to-purchase structure is an unconstitutional prior restraint on the Second Amendment.

Where the case stands, on the public docket as last retrieved August 11, 2026:

• Plaintiffs filed a First Amended Complaint on December 22, 2025.
• The state defendants and District Attorney Allen each moved to dismiss the amended complaint on March 3, 2026. Allen withdrew his motion and answered the complaint on May 8, 2026. The state defendants' motion has been fully briefed since May 1, 2026 and remains undecided.
• The scheduling order closes discovery on October 1, 2026, with dispositive motions due November 13, 2026 and a final pretrial conference set for November 30, 2026.
• No order enjoining any part of SB25-003 appears on the docket. In the August 10, 2026 joint filing, plaintiffs told the court they intend to file a preliminary injunction motion under Fed. R. Civ. P. 65 seeking facial and as-applied relief, and the parties proposed page limits and a briefing schedule for it. An injunction motion that has not been filed, let alone granted, changes nothing about your obligations today.

If you are an instructor, do not tell students an injunction is in place or is guaranteed to come. If you are a buyer, do not plan around an injunction that does not exist. Check the docket or CPW's page before you rely on any change.

Quick Reference

Where to Get Official Information

• CPW Specified Semiautomatic Firearms program page: https://cpw.state.co.us/specified-semiautomatic-firearms
• Firearms Safety System application portal: https://www.coloradofss.com/
• CPW Firearms Safety Program: 303-291-7143, dnr_cpw_firearmsafety@state.co.us
• Firearms Dealer Division (model guidance and statements of position): https://sbg.colorado.gov/firearms-dealer-division, dor_fdd@state.co.us, (303) 205-2989
• SB25-003 bill page: https://leg.colorado.gov/bills/sb25-003
• Your county sheriff's office, for the eligibility card, the local processing fee, and the county's list of verified firearms instructors