Colorado wildfire risk scores became appealable on July 1 — and condo policies are covered
Colorado wildfire risk scores became appealable on July 1 — and condo policies are covered
2026-09-10 · Colorado · Regulation
Since July 1, 2026, a Colorado insurer that uses a wildfire risk score has had to tell the policyholder the score, explain why the property got it, and answer an appeal within thirty days — and the statute expressly covers property insurance policies on residential condominium units. HB25-1182 was signed in May 2025 with a date-certain effective clause, and it applies to property insurance policies issued or renewed on or after July 1, 2026. It is live law now.1
For a Colorado association that has spent money on fuel reduction and defensible space and seen nothing back in premium, this is the mechanism the state built to change that.
The scope clause is the headline
New C.R.S. 10-4-124(10) says the section “applies only to homeowner's insurance policies as defined in section 10-4-110.6, property insurance policies covering residential condominium units as defined in section 38-33-103 (1), and multifamily residential housing as defined in section 24-32-3701 (9).” Subsection (9) adds that it applies to coverage provided by the Colorado FAIR Plan association. That is a rare Colorado insurance-transparency statute that does not stop at the single-family homeowner's policy.
Community mitigation has to count for something
The act defines a “community-level mitigation action” as a science-based mitigation action demonstrated by a community- or neighbourhood-level designation or certification, or undertaken by a government entity. A “property-specific mitigation action” is one demonstrated by the Insurance Institute for Business and Home Safety “Wildfire Prepared Home” designation or a similar programme with verification and certification.
Subsection (3) then requires an insurer using a wildfire risk model or catastrophe model to ensure that both property-specific mitigation and community-level mitigation activities — “including forest treatment and other fuel reduction activities” — are either built into the models or “otherwise demonstrably included in the insurer's underwriting and pricing.” Subsection (4) supplies the alternative: an insurer that does not build them in shall provide discounts to policyholders who demonstrate property-specific mitigation on the property, or community-level mitigation “in sufficient proximity to the property to reduce the risk of loss.”
The deadlines an insurer is held to
Subsections (6) and (7) turn disclosure into dates. An insurer that gives a mitigation discount, or that uses a wildfire risk model or score to underwrite, nonrenew, price, create a rate differential or surcharge, owes annual written notice of the applicable discounts, the wildfire risk score, and any other classification used — with a plain-language explanation, the range of possible scores, the property's relative position within that range, a written explanation of why the property received its score identifying the primary features that drove it, and the impact each mitigation action could have.
Delivery is on a schedule:
Applicants: no later than fifteen days after submission of a completed application.
Policyholders: in the offer of renewal.
Policyholders not being offered renewal: with the nonrenewal notice — so a nonrenewed association is entitled to see the score that produced the nonrenewal.
After new mitigation: no later than thirty days after a request for a revised score.
Subsection (8) creates the appeal. A policyholder or applicant whose score, classification or mitigation discount is inaccurate, and who provides evidence of the mitigation action, may appeal directly to the insurer. The insurer must acknowledge receipt in writing within ten calendar days and respond in writing with a reconsideration and decision within thirty calendar days. If it denies the appeal, it must forward the appeal and its response to the Commissioner on request.
Subsection (5) requires the insurer to post on its public website the mitigation actions that could earn a discount, incentive or premium adjustment, the amount of each, and the appeal process. That lets a board price the mitigation before spending on it.
What changes at the next renewal
This is the most actionable item of the year for a Colorado association in the wildland-urban interface, and the sequence is straightforward.
Demand the score and the written explanation. On an application it is due within fifteen days. On a renewal it must be in the renewal offer.
Inventory the community's mitigation and get it on paper. Fuel-reduction projects with dates, acreage, contractor, before-and-after photographs and invoices. Community or neighbourhood designations and certifications. Work done on adjacent land by the county, the fire district or the state — that is community-level mitigation the association did not pay for and can still point to.
Issue owners a standard evidence packet. The association's own mitigation work now has cash value to every member in proximity to it, but only if each owner can attach proof to a renewal or an appeal. Build the packet once; hand it out with the renewal calendar.
If mitigation has been completed since the last renewal, request a revised score. Thirty days for an answer.
If the score or the discount is wrong, appeal in writing and diary ten days for the acknowledgment and thirty for the decision.
For a condominium or attached community, run the same play on the master policy. Subsection (10) is what makes that possible — though whether a particular master-policy form falls inside “property insurance policies covering residential condominium units” is a question for the board's broker and counsel on that policy, not something a column can answer.
What to watch next
The Division of Insurance has built two regulations on top of this statute. Regulation 5-1-28, which takes effect October 1, 2026, is the consumer-facing half — and it names HOA-issued mitigation letters and community-level mitigation certificates as evidence an insurer must be willing to consider. Regulation 5-1-29, effective January 1, 2027, is the regulator-facing half, forcing carriers to show the Division in their rate filings exactly where mitigation sits in the model and to justify each discount actuarially.
Set expectations honestly, though. The Division's own analysis found wildfire mitigation currently has the potential to save a Colorado consumer an average of $3 to $25 a year, against $82 to $387 for hail mitigation — and drew the conclusion itself that the “lack of available discounts for wildfire mitigation work” means other solutions must be considered. Mitigation's value in availability — being offered a policy at all — is a separate and much larger question than its value in price.
Related Colorado HOA Topics
- HB25-1182 signed act text, new C.R.S. 10-4-124 (source of the quoted statutory language) ↩
- HB25-1182, "Property Insurance Underwriting Wildfire Risk Models" — bill page, Colorado General Assembly ↩
- Regulations Adopted But Not Yet Effective (Regulations 5-1-28 and 5-1-29), Colorado Division of Insurance ↩
- "Hail is the Number One Cost Driver of Insurance in Colorado" — Colorado Division of Insurance premium-share analysis ↩
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