In June 2026, Colorado enacted House Bill 26-1425, the Applied Behavior Analysis Practice Act. Almost all coverage focused on one provision: from July 1, 2028, an individual may not practice applied behavior analysis in Colorado without a state license.
The provision nobody covered sits in a different title of the code. The same act quietly rewrote the definition of day treatment facility in the child welfare licensing statute. It dropped the headcount threshold from five children to three, added a four hour daily floor, and redrew the purpose test to cover any program that assesses, treats, or promotes behavioral health, which the act now expressly defines to include autism spectrum disorder.
The effect: a center based ABA clinic serving three or more children for four or more hours a business day is now a day treatment facility under Colorado law. A clinic that was not captured on May 1, 2026 and is captured now had to submit a license application on or before August 1, 2026, and may not operate without a license on or after August 1, 2027. Home based, school based, and community based ABA are excluded.
As of the latest entry below, the Department of Human Services has published no guidance addressed to ABA operators on the day treatment capture. This dossier tracks the story from enactment forward.
Timeline, newest first
- 2026-06-27Live
Capture confirmed in the enrolled act
C.R.S. 26-6-903(8)(a)(I)A statute level read of the signed act confirms the amended day treatment definition drops the headcount threshold from five children to three and adds a four hour daily floor. Center based clinics not previously captured must apply by August 1.
- 2026-06-02
Governor Polis signs House Bill 26-1425 into law
Colorado Division of Professions and OccupationsGovernor Jared Polis signed House Bill 26-1425 into law, creating the Colorado Behavior Analyst Licensing Board within the Division of Professions and Occupations. Coverage centered on the individual license taking effect July 1, 2028. The facility provisions, which take effect on passage rather than in 2028, went unremarked. The three week gap between the bill reaching the Governor and the signing drew no particular attention to the facility language buried in the child welfare title.
- 2026-05-29
Bill sent to the Governor
Colorado General Assembly, HB26-1425 historyFollowing passage in both chambers, the enrolled bill was transmitted to the Governor for signature. The enrolled text is the version that carries the amended day treatment facility definition and the August 1, 2026 application deadline for newly captured facilities.
- 2026-05-15
Bill passes both chambers
Colorado General Assembly vote recordHouse Bill 26-1425 clears the House 45 to 19 and the Senate 32 to 3, en route to the Governor's desk.
- 2026-05-13
House passes on third reading, 45 to 19
Colorado General Assembly, House third reading voteThe House passed the bill on third reading by 45 to 19. The margin followed a genuinely contested path through committee, including a 6 to 5 vote in House Finance a few days earlier. The closeness of the committee votes concerned the licensure framework and appropriations, not the facility definition, which moved through the process without separate scrutiny.
- 2026-04-29
Clears first House committee
Colorado General Assembly, House Health and Human ServicesThe House Health and Human Services committee referred the bill onward by 8 to 5, the first of several committee steps. From introduction, the measure was framed and understood as a behavior analyst licensing bill. The amendment to the day treatment facility definition traveled inside it to enactment without ever becoming the headline.
ABAWiser provides research, analysis, and compliance advisory services. We are not a law firm, we do not provide legal advice, and no engagement creates an attorney client relationship. Dossiers track developments as they occur and may be incomplete or updated as a story evolves. Confirm any statutory or regulatory point against the primary source before acting on it.