During the most recent legislative session ending in May 2025, the Colorado General Assembly passed HB 25-1090: Protections Against Deceptive Pricing Practices. The new legislation, which takes effect on January 1, 2026, establishes new requirements for businesses offering goods or services, aiming to increase price transparency and protect consumers from deceptive pricing practices.

For accounting professionals and other service providers, the original bill language proposed in HB 25-1090 would have posed serious compliance challenges by requiring providers to disclose maximum price estimates upfront.  Given the highly variable nature of accounting engagements, this would have been especially burdensome, but thanks to proactive advocacy by the COCPA, a critical amendment was adopted, giving service providers greater flexibility while still meeting the bill’s intent. 

With less than four months until HB 25-1090 takes effect, here’s what accounting professionals offering services in Colorado need to know to prepare. 

Considerations in Preparing for Compliance 

While the law provides greater flexibility than originally proposed, it still introduces new disclosure requirements that will impact how accounting professionals and firms structure client communications, advertise pricing, and present fee proposals.  In this article, the COCPA highlights three key areas of focus to begin preparing for compliance: 

1. Client Proposals and Engagement Letters
2. Advertising and Online Pricing
3. Evaluating Pricing Structures.

Client proposals and engagement letters are often the first touchpoint where pricing transparency matters. Firms and individual practitioners should revisit these documents to ensure they clearly communicate what drives pricing. 

• Update all client proposals and engagement letter templates to clearly outline the factors that contribute to the final pricing. Such factors may include hourly rates, service timelines, deliverables, or scope of work.
• Add a disclaimer to future client proposals and engagement letters explicitly stating that total costs are subject to change based on individual client needs and modifications to scope of work. 
• Train staff involved in the preparation of client proposals and engagement so that everyone understands the new disclosure standards.

Because these documents form the legal foundation of your client relationships, it is recommended to work closely with your legal counsel or professional liability insurance provider before finalizing any changes.

HB25-1090 also affects how firms and professionals advertise pricing, including information on websites, third-party listings, and marketing materials.  This is an opportunity to ensure online references fairly reflect your services and pricing transparency. 

• Audit all platforms and materials (online or hardcopy) where pricing is displayed to confirm services and fees are presented transparently, including disclosures that clearly outline what specific services are included for the advertised fees in addition to any mandatory fees that may accompany the service.
• Update webpages displaying advertised prices or fees to include disclaimers about how the total costs may differ depending on scope and complexity or other factors when relevant. 
• Review existing marketing campaigns and email outreach to confirm what has been communicated about services and fees and update to new requirements.

If price listings that are non-compliant with HB 25-1090 have been prominently displayed for an extended period, practitioners may consider notifying prospective clients that they are in the process of modifying current listings to comply with new state law. 

With new pricing disclosure requirements, it may be worth taking a fresh look at your pricing model and considering how it aligns with HB 25-1090’s disclosure requirements. For firms and practitioners offering fixed-fee engagements, bundling multiple fees into one quoted price can simplify compliance.  However, for those who rely on variable rate pricing, firms and practitioners should continue explicitly outlining hourly rates for service, as well as clearly outlining the assumptions and factors influencing the scope of work and related total price. In addition, any administrative fees, processing fees, or other mandatory charges must be disclosed upfront so that clients have a complete picture of potential costs. Practitioners may estimate ranges, if helpful, so long it’s clear that the final total cost may change based on scope of work or client’s needs.  Simplifying pricing structures wherever possible not only supports compliance but also builds builds client confidence through greater clarity through greater clarity.

Looking Ahead: Enforcement and Ongoing Advocacy

Starting in 2026, HB 25-1090 will be enforced under the Colorado Consumer Protection Act by the by the Colorado Attorney General. While further rulemaking is possible, no additional guidance has been issued by the Attorney General to date.  The COCPA will continue monitoring activity related to HB 25-1090 to ensure members are aware of new developments that arise.

Reflecting on the successful amendment to HB 25-1090 for service providers, including CPAs whose services are unique in nature, COCPA CEO, Alicia Gelinas shared: 

 “This was a big win for CPAs, and it happened because we showed up, spoke up, and had the right relationships in place”.

COCPA’s advocacy successes, including the critical amendment to HB 25-1090, are made possible through ongoing member support and engagement from the CPA-PAC. 

To continue to support work to safeguard against unintended consequences for the accounting profession, educate lawmakers on the impacts to the profession, and ensure we have a seat at the table, consider supporting the CPA-PAC today. The CPA-PAC is bipartisan and focused on supporting candidates who will create a positive legislative and regulatory environment for you, your clients, and the profession. 

Looking to get more involved in advocacy? Stay tuned for details on the 2026 PAC the House event where you can have the chance to represent the accounting profession to represent the accounting profession at the Colorado State Capitol.

Disclaimer

This article is provided for informational purposes only and does not constitute legal advice. Practitioners should consult an attorney for specific guidance on compliance with HB 25-1090.