100,000 consumers
Controlling or processing personal data of 100,000 or more Colorado consumers in a year. Visitors with cookies and ad identifiers count.
Guide · US state law
Colorado was the first state after California to require sites to honor the browser's automatic opt-out signal. In this guide you will understand when the law applies to your site, what changes with the GPC and how the attorney general enforces it.
What it is
The Colorado Privacy Act, or CPA, was signed on July 7, 2021 and took effect on July 1, 2023. It follows the Virginia model, with consumer rights, opt-out of targeted advertising and consent for sensitive data.
The difference is in the details. The Colorado attorney general published his own rules, known as 4 CCR 904-3, which explain what the privacy notice must look like, how to ask for consent and how to recognize universal opt-out signals.
For a site with ads, the most important point is the universal opt-out mechanism. Since July 1, 2024, covered businesses must treat the Global Privacy Control, the GPC, as a valid request to opt out of targeted advertising and the sale of data.
The law works on an opt-out basis for ads. It does not require permission before showing personalized ads to adults, but it requires the opt-out to be simple, visible and automatic when the browser signals it.
Checklist
They apply to anyone who exceeds one of the thresholds of the Colorado law. The attorney general's rules detail each point.
Since July 1, 2024, anyone above the thresholds must accept GPC as an opt-out of sale and targeted advertising. Today, it is the only signal recognized by the state.
The path to opt out is in a clear, easy-to-find place, outside the privacy policy. The link must lead straight to the opt-out and make clear what it is for.
Footer: Your Privacy Choices or Your Colorado Privacy Choices
The policy explains how visitors exercise their rights and how GPC opt-outs are processed, and shows the date of the last update.
Last updated: March 2026. We respect Global Privacy Control as an opt-out of sale and targeted advertising.
Consent must be freely given, specific, informed and unambiguous. A pre-checked box does not count, and the person must be able to withdraw consent easily.
To accept GPC, the site cannot require login or ask for more data than strictly necessary.
Requests get a response within 45 days, with one extension of another 45 if the visitor is notified. The first access request in 12 months is free.
Before selling data, processing sensitive data or doing other high-risk processing, the company documents an assessment. The attorney general can ask for this document.
In the Colorado section of the GPP string, an opt-out of sale or targeted advertising turns on RDP. You can also turn on RDP directly in the tag.
// GPT: liga o processamento restrito de dados (RDP)
// para quem recusou a venda ou a publicidade direcionada
googletag.cmd.push(function () {
googletag.pubads().setPrivacySettings({
restrictDataProcessing: true
});
});In practice
Official tools
Google does not require a certified CMP for Colorado. Use Google's US states message or a CMP that reads GPC and generates GPP. These are the official links.
Who it applies to
The CPA applies to anyone who does business in Colorado or targets products and services to residents of the state and reaches one of the thresholds below. There is no revenue threshold.
Controlling or processing personal data of 100,000 or more Colorado consumers in a year. Visitors with cookies and ad identifiers count.
Processing data of 25,000 or more consumers and having revenue or a discount from the sale of data. Any revenue counts, there is no minimum percentage.
Since July 1, 2025, an amendment creates its own rules for identifiers and biometric data. Anyone who collects biometrics should check those rules separately.
The law protects residents acting in a personal or household context. Employee and business contact data are left out.
Definitions
Colorado defines sale more broadly than Virginia, and that brings the law closer to the reality of the ad market.
Information linked, or reasonably linkable, to an identified or identifiable person. De-identified and public data are left out.
Racial or ethnic origin, religion, health condition, sex life and sexual orientation, citizenship, genetic and biometric data and data of a child under 13.
The exchange of personal data for money or other value with a third party. Letting a partner collect data in exchange for a service can fall under this definition.
An ad chosen based on data about the person's activities over time on other companies' sites and apps. Contextual ads do not count.
Universal opt-out
The CPA created the concept of a universal opt-out mechanism: a signal sent by the browser or an extension that tells every site the person does not want targeted advertising or sale of data. That way, they do not have to click opt-out site by site.
The attorney general received applications at the end of 2023 and published the official list. So far, the only recognized mechanism is the Global Privacy Control. The state says the list may gain new names in the future.
Since July 1, 2024, businesses above the thresholds must honor the GPC. In practice, the site must detect the signal, treat the visitor as having opted out and pass that opt-out to all ad partners, without asking for an extra click.
The opt-out link is still needed. The law asks for the path to opt out to appear clearly in the privacy notice and also in a visible place outside it, such as the site footer.
Rights and obligations
A Colorado visitor can refuse targeted advertising, sale of data and certain profiling, as well as access, correct, delete and take their data to another service. The business has 45 days to respond, with another 45 if it notifies and explains the reason, and must offer an appeal path to anyone whose request is denied.
The privacy notice must say which categories of data are processed, for what purposes, which data goes to which categories of third parties and how to exercise rights. If there is sale or targeted advertising, this must be written clearly, along with the way to opt out.
Sensitive data can only be processed with consent. Colorado's rules require active, freely given, specific, informed and unambiguous consent. A pre-ticked box, silence or dark patterns do not count.
Since October 1, 2025, an amendment protects minors' data. Without the minor's own consent, or the parents' when under 13, the business cannot use their data in targeted advertising, sale and profiling tied to important decisions.
Timeline
Dates confirmed on the Colorado attorney general's pages and in published amendments.
The CPA is signed as SB 21-190.
The attorney general files the 4 CCR 904-3 rules, which detail notice, consent and opt-out.
The rights, the opt-out and the data protection assessments take effect.
Covered businesses must honor the universal opt-out mechanism recognized by the state.
The rule requiring notice with 60 days to fix before action ends.
The specific rules on identifiers and biometric data take effect.
The consent requirement for using minors' data in targeted ads, sale and certain profiling takes effect.
Assessments, enforcement and fines
The CPA can be enforced by the Colorado attorney general and the state's district attorneys. Individuals cannot sue the business under this law.
Until January 1, 2025, when the violation could be cured, the attorney general or district attorney had to send a notice and give 60 days for the fix. That mandatory period has ended. Today action can come without prior notice.
A CPA violation is treated as a deceptive trade practice under Colorado's consumer protection law. Under that law, the civil penalty reaches $20,000 per violation, and $50,000 when the victim is an elderly person. Each affected consumer can count as one violation.
High-risk activities, such as targeted advertising, sale of data and use of sensitive data, require a documented data protection assessment. The attorney general can request this document in an investigation.
AdSense and Ad Manager
AdSense and Ad Manager read the GPP string, the IAB Tech Lab format for privacy signals. For Colorado, Google accepts the state's own section and the US National section. When the string indicates an opt-out of sale or targeted advertising, Google turns on restricted data processing, RDP, and shows only non-personalized ads.
Google does not say it reads the GPC directly. That is why the safe path is for the CMP to detect the GPC, record the opt-out in the GPP string and only then release the ad tags. Another option is to turn on RDP in the tag itself, for example with restrictDataProcessing in GPT, for people who sent the signal.
The US states privacy message, in AdSense and Ad Manager, includes Colorado. It shows the opt-out link and saves the choice in GPP. Responsibility for complying with the law remains with the site.
If the site uses header bidding, video or social media pixels, the opt-out must reach those partners too. Turning off only Google is not enough.
In practice
Everyday examples from a site with ads and Colorado visitors.
Common errors
Most problems are in the gap between what the banner says and what the tags do.
The CMP honors the GPC for California, but ignores the signal for Colorado visitors.
The opt-out link exists, but the GPP string does not change and the ads stay personalized.
The notice talks about improving the experience, without saying there is targeted advertising or how to opt out.
Since 2025 there is no longer a mandatory 60-day notice. Waiting for a notification before acting is risky.
In ConsentMode
For personalized ads to adults, no. The law asks for an opt-out. Consent is required for sensitive data and, since October 2025, for using minors' data in targeted advertising.
It is a setting in browsers and extensions that sends sites an opt-out notice. Colorado recognizes the GPC as a universal opt-out mechanism, and covered sites have had to honor it since July 1, 2024.
Only if you pass 100,000 consumers in the state per year, or 25,000 with any revenue from selling data. Below that, most of the CPA does not apply. Anyone who collects biometrics should separately check the rules that have applied since July 2025.
The mandatory 60-day period ended on January 1, 2025. The attorney general can act directly.
No. ConsentMode is not a CMP and does not change the site. It simulates the visit with the GPC, shows whether the signal is honored and points to where to fix it.
Library
This guide was written from these official pages. Read them directly at the source:
The audit opens the site as a Colorado visitor and shows whether the opt-out reaches the ads, without changing anything.