Open workspace

Guide · US state law

The Colorado Privacy Act explained for people who live off ads

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.

  • ✓Based on the law, the rules and the Colorado attorney general's pages
  • ✓Examples designed for sites with AdSense and Ad Manager
  • ✓Read-only scan, no changes to the site
100,000Colorado consumers per year: the main threshold for the law to apply
1universal opt-out mechanism recognized by the state so far: the Global Privacy Control
$20,000maximum civil penalty per violation under Colorado's consumer protection law
45 daysdeadline to respond to consumer requests, extendable once by another 45

What it is

A short law with detailed rules from the attorney general

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

What you need to meet

They apply to anyone who exceeds one of the thresholds of the Colorado law. The attorney general's rules detail each point.

  1. Honor GPC

    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.

  2. Put the opt-out link outside the policy

    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.

    Example

    Footer: Your Privacy Choices or Your Colorado Privacy Choices

  3. Complete the privacy policy

    The policy explains how visitors exercise their rights and how GPC opt-outs are processed, and shows the date of the last update.

    Example

    Last updated: March 2026. We respect Global Privacy Control as an opt-out of sale and targeted advertising.

  4. Ask for active consent for sensitive data

    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.

  5. Do not require login or too much data

    To accept GPC, the site cannot require login or ask for more data than strictly necessary.

  6. Respond within 45 days

    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.

  7. Do the data protection assessment

    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.

  8. Pass the opt-out to Google

    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

Right and wrong

Official tools

Certified CMPs and official links

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

Two thresholds and no revenue figure

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.

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.

25,000 and revenue from sales

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.

Biometric rules

Since July 1, 2025, an amendment creates its own rules for identifiers and biometric data. Anyone who collects biometrics should check those rules separately.

Individual consumers only

The law protects residents acting in a personal or household context. Employee and business contact data are left out.

Definitions

The terms that weigh for people who sell ads

Colorado defines sale more broadly than Virginia, and that brings the law closer to the reality of the ad market.

Personal data

Information linked, or reasonably linkable, to an identified or identifiable person. De-identified and public data are left out.

Sensitive data

Racial or ethnic origin, religion, health condition, sex life and sexual orientation, citizenship, genetic and biometric data and data of a child under 13.

Sale

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.

Targeted advertising

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 GPC became an obligation on July 1, 2024

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

Visitor rights, privacy notice and consent

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

Colorado law dates

Dates confirmed on the Colorado attorney general's pages and in published amendments.

  1. July 7, 2021

    Law signed

    The CPA is signed as SB 21-190.

  2. March 15, 2023

    Final rules

    The attorney general files the 4 CCR 904-3 rules, which detail notice, consent and opt-out.

  3. July 1, 2023

    Entry into force

    The rights, the opt-out and the data protection assessments take effect.

  4. July 1, 2024

    GPC required

    Covered businesses must honor the universal opt-out mechanism recognized by the state.

  5. January 1, 2025

    End of the mandatory cure period

    The rule requiring notice with 60 days to fix before action ends.

  6. July 1, 2025

    Biometric data

    The specific rules on identifiers and biometric data take effect.

  7. October 1, 2025

    Under-18s

    The consent requirement for using minors' data in targeted ads, sale and certain profiling takes effect.

Assessments, enforcement and fines

Attorney general, district attorneys and fines of up to $20,000

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

How Google treats the Colorado visitor

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

What is and is not allowed in Colorado

Everyday examples from a site with ads and Colorado visitors.

Allowed

  • Show personalized ads to adults without asking permission first, while offering an opt-out
  • Automatically treat the visit of anyone with the GPC on as an opt-out
  • Keep an opt-out link in the footer, outside the privacy notice
  • Show contextual ads to people who opted out
  • Use Google's US states privacy message as a starting point

Not allowed

  • Ask a visitor with the GPC on to click again to confirm the opt-out
  • Leave the opt-out hidden only inside the privacy policy
  • Use a pre-ticked box to obtain consent for sensitive data
  • Use minors' data for targeted ads without consent
  • Pass data to header bidding partners after the opt-out

Common errors

Frequent failures on sites with Colorado visitors

Most problems are in the gap between what the banner says and what the tags do.

GPC only in California

The CMP honors the GPC for California, but ignores the signal for Colorado visitors.

Opt-out on paper only

The opt-out link exists, but the GPP string does not change and the ads stay personalized.

Generic policy

The notice talks about improving the experience, without saying there is targeted advertising or how to opt out.

Counting on the cure period

Since 2025 there is no longer a mandatory 60-day notice. Waiting for a notification before acting is risky.

In ConsentMode

What the audit checks about the CPA

  • Opens the site as a Colorado visitor with the GPC off and on and compares what changes on the page and in the ad requests.
  • Reads the GPP string and shows whether the Colorado section or the US National section indicates the opt-out when the GPC is on.
  • Looks for the opt-out link in a visible place outside the privacy policy.
  • Identifies the CMP and checks that the ad and header bidding tags wait for its response.
  • Reads the privacy policy and points out whether purposes, third parties, rights, appeal and the way to opt out are missing.

Frequently asked questions about the Colorado law

Do I need a consent banner for Colorado?

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.

What exactly is the GPC?

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.

My site has few Colorado visitors. Does the law apply?

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.

Do I still get a cure period before a fine?

The mandatory 60-day period ended on January 1, 2025. The attorney general can act directly.

Does ConsentMode turn on the GPC on my site?

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

Official sources

This guide was written from these official pages. Read them directly at the source:

Test your site with the GPC on

The audit opens the site as a Colorado visitor and shows whether the opt-out reaches the ads, without changing anything.

Start the audit