Colorado · HB25-1090 effective January 1, 2026

Colorado commercial tenants: check your CAM bill against public data

Colorado just cracked down on hidden pass-through fees with HB25-1090, and advocates are pushing to extend transparency protections to commercial small-business tenants. Here's what the law does, what's coming, and how to check your own operating-cost bill — free.

Informational only · Not legal advice · Consult a Colorado commercial real estate attorney

What HB25-1090 does

Colorado HB25-1090 (the Deceptive Pricing / junk-fee law), effective January 1, 2026, limits the markup a landlord can add to third-party pass-through fees to the lesser of 2% of the landlord's actual cost or $10 per month, and requires clearer total-price disclosure. It is the second state law — after California's SB 1103 — signaling that opaque pass-through fees on tenants are a recognized harm.

Be precise: HB25-1090's strongest fee protections are consumer/residential. Colorado does not yet have a dedicated commercial CAM-documentation statute like California's SB 1103 — commercial CAM disputes here are governed by your lease and contract law. The commercial extension below is proposed, not yet enacted.

What's coming for commercial tenants

Small-business advocates and Colorado lawmakers are working on legislation to extend pass-through transparency — including insurance and property-tax pass-throughs — to commercial small-business tenants. Colorado small businesses have publicly reported operating-cost fees climbing sharply, sometimes with large surprise back-charges. The momentum is real: California enacted SB 1103, Colorado enacted HB25-1090, and a commercial follow-on is being drafted for the next session.

You don't have to wait for the law to verify your own bill. The math and the public records are already available.

Where Colorado CAM bills go wrong

Pro-rata share inflation

You're billed a larger share of building costs than your floor area supports — the single most common, highest-dollar error.

Fixed costs grossed up

In a partly-vacant building, only variable costs may be grossed up to a stabilized occupancy. Insurance, security, and management fees often shouldn't be.

Line items above the index

A category that rose far faster than its published cost index (e.g. janitorial or insurance jumping well above the BLS producer-price index) is worth a closer look.

Non-recoverable charges

Capital improvements, the landlord's own taxes, or marketing fees slipped into the CAM pool that your lease may not permit.

Check your bill against public data — free

Type a few numbers from your lease and most recent reconciliation. ReCAM cross-checks the math against public data — county building size, the landlord's own filings, and BLS cost indexes — and flags charges that don't add up. No upload, no sign-up, plain-English. It's informational: you take any finding to your own attorney or auditor.

Frequently asked questions

Does Colorado have a commercial CAM / pass-through law?
Colorado enacted HB25-1090 (the Deceptive Pricing / junk-fee law), effective January 1, 2026, which brought pass-through-fee transparency and markup limits to Colorado. Its strongest fee protections are consumer/residential; an effort is underway to extend transparency protections to commercial small-business tenants, but as of now Colorado does not have a dedicated commercial CAM-documentation statute like California's SB 1103. Commercial CAM disputes in Colorado are governed by your lease and contract law — consult a Colorado attorney.
What does HB25-1090 actually do?
HB25-1090 limits the markup a landlord can add to third-party pass-through fees (such as trash, internet, or pest control) to the lesser of 2% of the landlord's actual cost or $10 per month, and requires clearer total-price disclosure. It is the second state law (after California's SB 1103) signaling that opaque pass-through fees on tenants are a recognized harm.
How do I check my Colorado CAM / operating-cost bill?
Start with three free checks you can do yourself: (1) does the pro-rata share you're billed match what your lease grants; (2) does the building size on your statement match the county's recorded square footage; (3) did any line item rise far faster than its market cost index (for example, did janitorial or insurance jump well above the published producer-price index for that service). ReCAM runs these cross-checks against public data for free — informational, for your own review.
Is my Colorado lease triple-net (NNN) or full-service?
If your lease passes operating costs through separately (taxes, insurance, common-area maintenance), it is triple-net or modified-gross and you receive a periodic reconciliation worth checking. If it is full-service-gross, those costs are bundled into rent. ReCAM's cross-check is most useful when you receive a separate CAM/operating-cost reconciliation.
What can I do about a CAM overcharge in Colorado?
Gather your lease and reconciliation, identify charges that do not match your lease or public records, request the supporting documentation your lease allows, and take any defensible discrepancy to your own attorney or a CAM auditor. ReCAM produces a mathematically-cited cross-check to support that conversation — it is not legal advice and not an audit.

Informational only · Not legal advice. This page explains Colorado HB25-1090 and how ReCAM's public-data cross-check works. It is not legal advice and does not create an attorney-client relationship. Colorado does not yet have a dedicated commercial CAM statute; consult a Colorado commercial real estate attorney for guidance on your lease.