Colorado Now Logs Every Retail Gun Transfer: What HB26-1126 Means for FFL Dealers and Online Sellers

Colorado’s HB26-1126 puts every retail firearm sale and transfer on the state dealer log. Here’s what changed, what’s still proposed, and the dates to watch.

Giancarlo Byrne

10/20/2026

Colorado Now Logs Every Retail Gun Transfer: What HB26-1126 Means for FFL Dealers and Online Sellers

If you run a transfer counter in Colorado, or you ship online orders to dealers there, the paperwork changed this summer. Colorado’s HB26-1126 was signed on June 2, 2026 and took effect the same day. It turned the state’s old handgun-only dealer record into a record of every retail firearm transaction, and it says plainly that transfers count.

The state’s Firearms Dealer Division (FDD) is now writing the rules that fill in the details, with a hearing set for October 30. Here is what the law already requires, what is still only proposed, and what you can do now.

What the law changed on June 2

Before HB26-1126, Colorado’s dealer record under C.R.S. 18-12-402 covered pistols and revolvers. The new version covers every retail firearm transaction other than destructive devices, “including the sale, rental, or exchange, or transfer” of the gun. It applies to transactions on or after June 2, 2026.

Each record has to be made at the time of the transaction, in a book or an electronic record, and include:

The name, age, and address of the person who received the firearm
The make, caliber, and finish of the firearm
The serial number
The date of the transaction
The name of the employee who conducted it

The law also states that the department and other state agencies may not use these records to build a registry of firearm ownership. Failing to keep the record, or refusing to show it to a peace officer, is a class 2 misdemeanor under 18-12-403.

This state record sits on top of the federal 4473 and the background check. It does not replace either one.

Transfers are now clearly in scope

The bill also widened who counts as a “dealer.” The definition now covers a federal licensee who sells at retail or who transfers firearms to the public as part of a retail transaction. That expressly includes private-sale background-check transfers under C.R.S. 18-12-112.

For ecommerce, this is the part that matters most. When a Colorado FFL receives an online-ordered gun and hands it to the buyer, that handoff is a logged retail transfer. The same goes for a private-party transfer run through the counter.

A few other pieces of the law are worth knowing:

Dealers must report the theft or loss of a firearm to the department within 48 hours of learning about it.
Large-capacity magazines must be kept behind a counter or in a locked case or room.
The state permit language now reaches anyone who transfers firearms “into or out of this state.” More on that below.

What the FDD is proposing

The Division already revised its forms on June 26, 2026, including the Transaction Log (DR 7602), the Addendum (DR 7603), and the A&D Record (DR 7606). The new forms add categories such as shotgun, rifle, frame or receiver, silencer, and weapons parts kit, and they drop gender, race, occupation, and the model field.

Its proposed rule changes to 1 CCR 214-1 go further. These are proposals, not final rules, but they show where things are heading:

Who needs a state permit. The draft lists Types 01 and 02 and any other licensee that sells or transfers at retail to the public, naming Types 07, 08, 09, 10, and 11. It calls for a separate permit for each premises and each FFL.
What goes on the log. The draft adds the recipient’s date of birth and an affirmation that the person is 21 or older. It requires a physical residential address and says P.O. boxes are not acceptable.
Security plans. The law requires dealers to follow a submitted security plan starting October 1, 2027. The draft rule fills that in with a menu of structural, electronic, and business-practice measures. In its October 15 responses to working-group comments, the Division said home-based and rural dealers do not have to adopt every listed measure.
Ammunition. A dealer that also sells ammunition at retail would keep it out of reach without staff help and could not sell it to anyone under 21.

Dates to put on the calendar

June 2, 2026: HB26-1126 took effect. The all-firearms record applies from this date.
October 26, 2026, 5 PM MT: Written comments due for review before the hearing.
October 30, 2026, 1:00 to 3:55 PM MT: Rulemaking hearing in Lakewood and on Zoom (hearing notice).
November 2, 2026, 5 PM MT: Last day for written comments to be part of the record.
January 1, 2027: A second or subsequent offense on or after this date can draw a fine of up to $75,000.
October 1, 2027: Security plan measures must be in place.

Comments go to dor_fddrulemaking@state.co.us, according to the hearing notice.

What isn’t settled yet

The law says a dealer needs a state permit to transfer firearms “into or out of this state.” It’s natural to wonder whether that reaches an out-of-state FFL that ships guns to Colorado dealers. We could not find an answer. The proposed rules don’t address out-of-state licensees, and we found no FDD guidance on it.

If that question matters to your business, ask the FDD directly, follow the October 30 hearing, and talk with a firearms attorney before building a plan around it.

Practical steps by role

Colorado transfer dealers

Make sure your log covers every firearm transaction since June 2, not just handguns, and that it includes transfers of online orders and private-party background checks.
Use the June 26 versions of the FDD forms.
Start asking for date of birth and a full residential address now, since the proposed log would require both.
Write down your 48-hour theft and loss reporting process so staff know who files it.
Start sketching your security plan. Structural changes take time and money.
Review your transfer fee. Logging every transfer is real work, and it’s reasonable to price it in.

Online sellers shipping to Colorado dealers

Pass clean buyer data to the receiving dealer: full legal name and a residential address, not a P.O. box. That makes their log entry easier and the pickup faster.
Confirm current transfer fees and policies with the Colorado dealers your customers choose most often.

Colorado-based online stores

Consider collecting date of birth at checkout so you have it when the transaction is logged.
Keep order records in a format that maps cleanly to the fields on the DR 7602 log.
Watch the hearing outcome before rebuilding your checkout around the proposed rules. Details can change between the draft and the final version.

Where Automatic FFL fits

Automatic FFL lets your shoppers choose a licensed dealer during checkout. Colorado’s logging, permit, and age requirements sit with that dealer and with your own store setup, so check with them and with counsel on anything state-specific. Setup details are in our documentation.

The bottom line

The all-firearms record is already law in Colorado, and it applies to transfers. The date-of-birth field, the 21+ affirmation, the P.O. box ban, and the security plan details are still proposals until the FDD adopts final rules. If you have a stake in how they land, the comment window closes November 2.

This article is general information, not legal advice. For questions about your specific license or business, talk with a firearms attorney or contact the Colorado Firearms Dealer Division.

Sources

Back to Blog