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Colorado, USA
US-COschema crypto-v2.0.0trajectory: not yet assessedregulatedoverlaps: FIM, WPM
Last updated · 8 categories · 12 sourced
findings · 17 sources in the cumulative register
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Jurisdiction lead brief
Lead Signal
Colorado's crypto-adjacent regulatory perimeter tightened structurally this cycle through two coordinated instruments. The Money Transmission Modernization Act (HB25-1201) confirms that fiat-linked virtual-currency transmission in Colorado is regulated under the state's general money-transmission licensing framework, codified at Title 11, Article 110 of the Colorado Revised Statutes and administered by the Colorado Division of Banking; there is no separate, stand-alone crypto licence class. Alongside it, the Colorado Vending of Digital Assets Act (SB25-079) reached its effective date of 2026-08-12, creating a narrower, kiosk-specific regime: owners and operators of virtual-currency kiosks are now subject to disclosure, receipt, and conditional refund duties. The refund duty is conditioned on a defined cross-border trigger, applying where a customer's first transaction moved funds to a wallet or exchange located outside the United States and the customer reports suspected fraud within 60 days with law-enforcement contact. Both developments are assessed with High confidence against Tier 1 primary legislative sources and are now in force rather than merely proposed or enacted-but-pending.
Other Developments
The consumer-protection dimension of SB25-079 stands as a distinct, binding development in its own right: kiosk operators must provide certain disclosures and issue an electronic receipt detailing each customer transaction, a direct statutory duty rather than voluntary industry practice. This narrow but binding requirement applies specifically to the kiosk channel of crypto access, leaving virtual-currency exchanges and custodial platforms outside its scope. For firms currently licensed as Colorado money transmitters, the relevant question raised by SB25-079 is layering, not substitution: the kiosk-specific duties apply on top of, not instead of, any money-transmitter licensing obligation that already governs a kiosk operator's fiat-linked virtual-currency activity. Colorado's crypto regulatory perimeter continues to run through general money-transmission licensing rather than a bespoke crypto licence, with SB25-079's kiosk regime standing as the only dedicated crypto-specific instrument identified this cycle. No enforcement action under either HB25-1201 or SB25-079 has been identified this cycle, which is consistent with the short interval since SB25-079's effective date and does not itself indicate an absence of compliance activity.
Cross-Monitor Connections
The same underlying statutes driving this cycle's crypto-licensing and consumer-protection signal for Colorado also carry direct relevance for the world-payments and financial-integrity monitors. HB25-1201's money-transmission licensing overhaul is, from a payments-market-structure perspective, a licensing and market-access development bearing on non-bank payment institutions generally, a reading that belongs to the world-payments monitor's own licensing lens rather than to this crypto-specific brief. Separately, the fraud-typology and disclosure control embedded in SB25-079's kiosk-refund mechanism carries an AML/CFT-adjacent reading that the financial-integrity monitor addresses under its own digital-assets domain; this brief treats the same statute strictly as a crypto-licensing and consumer-protection development, without re-analyzing its anti-money-laundering dimension. This layering across three monitors is expected rather than anomalous: a single statute can carry a licensing-and-market-access reading, a crypto-consumer-protection reading, and an AML/CFT-adjacent reading simultaneously, each properly assigned to the monitor whose typology it falls within.
Outlook
The Colorado Division of Banking is anticipated to issue guidance clarifying the scope of the modernized money-transmission statute over non-custodial and decentralized-finance activity, and detailing kiosk-operator compliance expectations under SB25-079, with an expected timeframe in the fourth quarter of 2026. Until that guidance issues, the central open question for Colorado's crypto regulatory perimeter is whether activity outside the custodial, kiosk-based model identified this cycle falls within the modernized statute's scope at all. Analysts should also track whether other states adopt a comparable kiosk-specific consumer-protection and cross-border-refund model, since Colorado's approach is currently the only such instrument identified for this jurisdiction.
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Colorado has no bespoke crypto-asset licensing statute. Virtual-currency exchange, custody, and transmission businesses operating in or serving Colorado residents fall under the state's general Money Transmitters Act (C.R.S. Title 11, Article 110), administered by the Colorado Division of Banking and processed through the Nationwide Multistate Licensing System (NMLS). Federal FinCEN MSB registration attaches in parallel for any entity accepting and transmitting convertible virtual currency. The precise statutory citation and the existence of any crypto-specific carve-outs within the MTL regime were not independently confirmed against the current C.R.S. text in this research pass and should be verified.
Standing sub-brief197 words · last cycle 2026-09-21
Crypto Licensing
Colorado regulates fiat-linked virtual-currency transmission through its general money-transmission licensing framework rather than a bespoke crypto licence. The Money Transmission Modernization Act (HB25-1201) confirms that such activity falls under the state's money-transmission licensing regime, codified at Title 11, Article 110 of the Colorado Revised Statutes, administered by the Colorado Division of Banking. Layered on top of this general licence, the Colorado Vending of Digital Assets Act (SB25-079) creates a narrower kiosk-operator regime: owners and operators of virtual-currency kiosks, commonly known as crypto ATMs, are subject to disclosure, receipt, and conditional refund duties, effective 2026-08-12. This is the only bespoke crypto-specific licensing instrument identified in Colorado; the general money-transmission licence remains the primary vehicle through which fiat-linked crypto transmission is regulated. Whether the Division of Banking treats non-custodial or decentralized-finance activity as falling within the scope of the modernized money-transmission statute remains unconfirmed this cycle, and is the central open question for this module going forward.
Outlook
Anticipated Division of Banking guidance, expected in the fourth quarter of 2026, is likely to clarify the scope of the modernized money-transmission statute over non-custodial and decentralized-finance activity, and to detail kiosk-operator compliance expectations under SB25-079 in more depth.
Periodic update · new data 2026-09-22
Crypto Licensing
Colorado has no bespoke crypto-licensing statute; virtual-currency businesses are captured, where applicable, under the general money-transmission licensure framework now governed by the Money Transmission Modernization Act (MTMA), C.R.S. Title 11, Article 110. The MTMA was enacted through HB25-1201, which repealed and reenacted the prior Colorado Money Transmitters Act effective August 6, 2025, aligning Colorado's statute with the CSBS multistate model law. This reenactment itself is confirmed and durable in the statute, though the crypto-specific application of the licensing test was, until this cycle, a matter of some ambiguity.
That ambiguity was substantially narrowed by interim guidance issued by the Colorado Division of Banking on December 18, 2025, confirming that persons engaged in buying, selling, or facilitating transfer of virtual currency within Colorado may require an MTMA license depending on the specific transaction model at issue. This guidance is confirmed and currently in force, though it is guidance rather than statute, meaning its precise interpretive boundaries could be revised by the Division without a full legislative process. The practical effect for crypto-asset operators is a clearer, though not yet fully codified, test for whether their specific business model — exchange, custody, transmission — triggers licensure.
Outlook
Watch for whether the Division of Banking's interim guidance is eventually codified into formal rule, and for whether Colorado's 2019 Digital Token Act securities exemption continues to operate alongside the reenacted MTMA, a question not confirmed this cycle.
1 earlier distinct update(s)
Periodic update · new data 2026-09-14
Crypto Licensing
Colorado's Division of Banking issued interim guidance on December 18, 2025, interpreting the Money Transmission Modernization Act as generally requiring a Money Transmitter License for persons buying, selling, or facilitating transfer of virtual currency within Colorado. This is a confirmed, Tier-1-sourced finding directly from the primary regulator, and it resolves what had previously been an interpretive question: virtual-currency businesses now fall unambiguously within the state's existing money-transmission licensing perimeter. The guidance is explicitly interim in character, meaning it represents the Division's current interpretive position rather than a finalized rule, a distinction that matters for firms assessing the durability of this licensing requirement.
Secondary law-firm commentary corroborates the broader statutory context: the Money Transmission Modernization Act broadened Colorado's money-transmission licensing scope to cover digital money movement and payroll processing in addition to virtual currency, modeled on the Conference of State Bank Supervisors' multistate licensing framework. This is a probable-confidence, Tier-3-sourced characterisation of legislative intent, corroborating but not independently verifying the primary regulator's interim guidance. Taken together, these two sources indicate that Colorado has extended an existing, multistate-aligned money-transmission licensing structure to explicitly reach virtual-currency activity, rather than constructing a separate, crypto-specific licensing category from first principles. Licensees under this route are subject to the same conditions applicable to any Colorado money transmitter: NMLS registration, bonding, net-worth requirements, and a BSA/AML-program obligation with independent review.
Outlook
The central open question is whether the December 2025 interim guidance will be finalized into permanent rule, and on what timeline; this was not confirmed this cycle. Firms operating or planning to operate virtual-currency businesses in Colorado should treat the licensing requirement as the current operative standard while monitoring for the guidance's conversion to final form, which would materially increase confidence in its durability as a settled regulatory requirement rather than an interpretive position.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (3)
T1 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — Businesses that exchange, transmit, or custody convertible virtual currency on behalf of Colorado residents must obtain a Colorado money transmitter license under the state's general Money Transmitters Act, since Colorado has no separate crypto-specific licensing statute.retrieved M5bindingin force
T1 · Financial Crimes Enforcement Network (FinCEN), U.S. Department of the TreasuryFinancial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury — Persons acting as administrators or exchangers of convertible virtual currency operating in Colorado are independently required, like any money transmitter, to register with FinCEN as a money services business under federal law, in addition to any state licensing obligation.retrieved M4bindingin force
T1 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — Colorado state money-transmitter licensing addresses money-transmission and custody activity only; it does not itself determine whether a given token is a security or commodity, a question governed separately by federal SEC/CFTC jurisdiction.retrieved M3non-binding
Colorado has historically explored a state-level securities exemption for consumptive-purpose digital tokens (the proposed Colorado Digital Token Act), but this research pass could not independently confirm current in-force codification, so its present statutory status is flagged for verification. Absent a confirmed bespoke state carve-out, token characterization in Colorado is effectively driven by federal SEC/CFTC frameworks, which as of 2026 distinguish digital commodities, collectibles, and tools (generally not securities) from tokenized instruments issued or structured as investment contracts (which remain securities regardless of on-chain format).
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (3)
T4 · CoinDeskCoinDesk — A 2019 Colorado legislative proposal, the Digital Token Act, sought to exempt digital tokens with a primarily consumptive purpose (not marketed for speculative or investment purposes) from state securities registration requirements, subject to an issuer notice filing with the state securities commissioner; whether this proposal was enacted and remains part of current Colorado Revised Statutes was not independently confirmed in this research pass.retrieved M4non-bindingour coverage gap, expected to resolve on a re-run
T2 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Current SEC leadership guidance (2026) articulates that digital commodities, digital collectibles, digital tools, and payment stablecoins under the GENIUS Act are generally not deemed securities, narrowing federal securities-law scope to tokenized instruments structured as investment contracts.retrieved M3non-binding
T2 · U.S. Securities and Exchange Commission, Division of Corporation FinanceU.S. Securities and Exchange Commission, Division of Corporation Finance — Regardless of whether a security is issued or recorded on-chain versus off-chain, every offer and sale of a security must be registered with the SEC unless a registration exemption applies, meaning tokenized securities remain fully subject to federal securities law in Colorado as elsewhere.retrieved M4bindingin force
No Colorado-specific statute or regulation addressing staking, DeFi lending, DEX operation, mining, node/validator operation, or tokenization was identified in this research pass. These activities in Colorado are governed, if at all, by the same general federal frameworks (SEC/CFTC characterization, FinCEN money-transmission analysis) that apply nationally, with no additional state-level overlay found. This is recorded as a jurisdictional gap pending further primary-source research rather than a confirmed absence of any obligation.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
Colorado has no identified state-specific stablecoin issuance, reserve, or redemption regime. Payment stablecoins circulating in Colorado are governed at the federal level under the GENIUS Act framework, which SEC leadership guidance treats as placing payment stablecoins outside the scope of federal securities law as a distinct asset category.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Payment stablecoins circulating in Colorado are subject to the federal GENIUS Act framework, under which SEC guidance treats such instruments as a distinct, generally non-security asset category rather than as securities requiring state-level issuance authorisation.retrieved M3bindingin force
No bespoke crypto consumer-protection statute for Colorado was identified in this research pass. General consumer protections likely apply via the state's general deceptive-trade-practices law and via the surety-bonding, net-worth, and permissible-investment conditions typically attached to money-transmitter licensure, but the specific text and applicability of these provisions to crypto licensees was not verified against primary sources in this pass.
Standing sub-brief139 words · last cycle 2026-09-21
Consumer Protection
Colorado imposed new, binding consumer-protection duties on virtual-currency-kiosk operators this cycle. The Colorado Vending of Digital Assets Act (SB25-079) requires kiosk operators to provide certain disclosures to customers and to issue an electronic receipt detailing each customer transaction, effective 2026-08-12. This is a direct statutory duty rather than voluntary industry practice, and it applies specifically to the kiosk-operator channel of crypto access rather than to virtual-currency exchanges or custodial platforms generally. The disclosure and receipt requirements are narrowly scoped to the kiosk-transaction context but are binding and enforceable as part of Colorado's broader money-transmission and vending-of-digital-assets statutory framework.
Outlook
No further consumer-protection rulemaking or guidance specific to virtual-currency kiosks has been identified as pending this cycle beyond the anticipated Division of Banking guidance addressing the broader money-transmission and kiosk framework expected in the fourth quarter of 2026.
Periodic update · new data 2026-09-22
Consumer Protection
Consumer protection for virtual-currency businesses in Colorado derives entirely from the general money-transmission consumer-protection framework under the Money Transmission Modernization Act rather than from any crypto-specific overlay. MTMA licensees, including in-scope virtual-currency businesses, must forward funds timely and provide receipts containing specific transaction information, a probable and currently in-force obligation effective alongside the broader statutory reenactment on August 6, 2025. This is a general money-services consumer-protection requirement applied to crypto businesses only by virtue of their falling within the MTMA's money-transmission definition; no bespoke crypto consumer-protection rule was identified this cycle.
The absence of a crypto-specific overlay means consumers transacting with Colorado-licensed virtual-currency businesses receive the same fund-forwarding-timeliness and receipt-disclosure protections as consumers of any other MTMA-licensed money transmitter, no more and no less. Where a virtual-currency business model falls outside the MTMA's money-transmission definition entirely, such as certain forms of on-chain activity, no consumer-protection framework was identified as applying to it at the state level this cycle.
Outlook
Watch for whether future Division of Banking guidance introduces any crypto-specific consumer-protection provisions distinct from the general MTMA fund-forwarding and receipt-disclosure requirements.
1 earlier distinct update(s)
Periodic update · new data 2026-09-14
Consumer Protection
The Colorado Vending of Digital Assets Act (SB25-079) imposes disclosure and fraud-refund duties on virtual-currency kiosk operators. Under the Act, kiosk operators must provide customer disclosures and issue an electronic transaction receipt for each transaction, and must refund a customer's first transaction to an out-of-US wallet or exchange if that transaction is reported as fraudulent within 60 days. This is a Tier-1-sourced, primary-statute finding assessed at probable confidence: the statute's existence and core provisions are confirmed at the primary-source level, but the precise effective date of these requirements was not independently confirmed this cycle.
This instrument targets a specific, narrow channel within the broader virtual-currency ecosystem: the physical kiosk or ATM point of transaction, which is a recognised locus of consumer-fraud risk given the typically cash-based, high-friction-to-reverse nature of kiosk transactions. The disclosure requirement addresses information asymmetry at the point of sale, while the 60-day fraud-refund mechanism provides a defined, time-bound recourse pathway for customers whose first kiosk transaction is fraudulently induced and directed to an out-of-US wallet or exchange. The provision is notably narrow in scope, applying specifically to first transactions and to the out-of-US-destination fact pattern, rather than establishing a general kiosk-transaction refund right.
Outlook
The unresolved item this cycle is confirmation of SB25-079's precise effective date, which affects when kiosk operators must have these disclosure and refund mechanisms operationally in place. Kiosk operators active in Colorado should treat the disclosure and refund obligations as current law given the Tier-1 statutory sourcing, while awaiting confirmation of the exact compliance timeline.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (2)
T1 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — Colorado-licensed money transmitters handling convertible virtual currency are presumptively subject to the state MTL's general permissible-investment and surety-bond conditions intended to protect customer funds, though no crypto-specific custody-segregation rule was separately confirmed.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
T1 · Nationwide Multistate Licensing System (NMLS)Nationwide Multistate Licensing System (NMLS) — General Colorado deceptive-trade-practices consumer protection law would presumptively apply to misleading crypto marketing claims, but no crypto-specific marketing restriction was identified or verified in this research pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
Colorado is one of a small number of U.S. states that formally accepts cryptocurrency for state payments. Since September 2022, the Colorado Department of Revenue has accepted crypto payments (via a third-party processor, PayPal) for personal income tax, business income tax, severance tax, and withholding tax, with the state converting proceeds to USD rather than holding crypto directly. Substantive income/capital-gains tax treatment of crypto held by Colorado taxpayers was not independently confirmed in this pass and is presumed to follow Colorado's general conformity to federal taxable income absent a state-specific carve-out.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (2)
T4 · CoinDeskCoinDesk — Since September 2022, the Colorado Department of Revenue has accepted cryptocurrency payments (via PayPal) for personal income tax, business income tax, severance tax, and withholding tax, with the state not directly holding crypto assets.retrieved M3bindingin force
T4 · CoinDeskCoinDesk — Colorado income tax liability on cryptocurrency gains and income is presumed to follow the state's general conformity to federal taxable income, absent an identified state-specific crypto tax carve-out; this was not independently verified against Colorado Department of Revenue primary guidance in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
No Colorado-specific outbound restriction, reporting threshold, or travel-rule overlay for cross-border crypto transfers was identified. Cross-border movement of convertible virtual currency to or from Colorado-based persons is governed by the same federal frameworks (FinCEN Travel Rule, OFAC sanctions screening) that apply uniformly across the United States, with no additional state-level layer found.
Standing sub-brief130 words · last cycle 2026-08-21
Cross-Border Transfer
Colorado's only cross-border-relevant crypto-transfer provision identified this cycle arises from the kiosk-operator refund mechanism under the Colorado Vending of Digital Assets Act (SB25-079). The statute conditions a kiosk-operator refund obligation on the customer's first transaction having moved funds to a wallet or exchange located outside the United States, effective 2026-08-12. This is a narrow, transaction-specific cross-border trigger rather than a general cross-border-transfer regime: it does not impose reporting, licensing, or capital-control obligations on cross-border virtual-currency transfers generally, but it does create a defined consumer-protection remedy specifically keyed to the destination of a kiosk transaction being outside the United States.
Outlook
Whether Colorado extends cross-border-specific crypto-transfer obligations beyond the narrow kiosk-refund trigger identified this cycle remains to be seen; no such expansion is currently signaled in the regulatory horizon.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (1)
T1 · Financial Crimes Enforcement Network (FinCEN), U.S. Department of the TreasuryFinancial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury — Colorado imposes no identified state-level outbound restriction on cross-border convertible virtual currency transfers; such transfers involving Colorado-based persons are subject to the same federal BSA/FinCEN obligations that apply equally to domestic and foreign-located CVC money transmitters doing business in the United States.retrieved M2bindingin force
AML/CFT obligations applicable to Colorado-facing crypto businesses (KYC/CDD, travel rule, SAR/STR filing, sanctions screening, recordkeeping, risk assessment) are governed at the federal level by FinCEN/BSA rules and are tracked under the fleet's Financial Integrity Module (FIM) aml_ctf subscription rather than duplicated in this crypto consumer baseline, per module subscription doctrine.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
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