Crypto Law Profile
Colorado applies its money transmission framework to fiat-linked crypto transmission. HB25-1201 replaced the prior Money Transmitters Act with the MTMA, effective Aug. 6, 2025.
Colorado’s money transmission virtual currency regime is the state’s application of Title 11, Article 110 of the Colorado Revised Statutes to money transmission activity, including certain crypto-related business models. As of June 9, 2026, the operative statute is the Money Transmission Modernization Act, enacted through HB25-1201 and effective August 6, 2025. The 2025 act repealed and reenacted Article 110, replacing the prior Colorado Money Transmitters Act while preserving a money-transmission licensing framework administered by the Colorado Banking Board and Division of Banking.
This profile treats the regime as the current statutory framework, the implementing rules in 3 CCR 701-7, and the Division of Banking’s 2018 interim cryptocurrency guidance. The 2018 guidance is important because it explains how the Division viewed cryptocurrency transactions under the pre-2025 Act, but editors should recheck whether the Division has updated or withdrawn that guidance under the MTMA.
HB25-1201 defines the current article’s short title as the Money Transmission Modernization Act. The stated purposes include coordinating licensing and supervision among states, protecting the public from financial crime, standardizing licensed and exempt activities, and modernizing safety-and-soundness requirements for customer money.
Under the current text, “money transmission” includes selling or issuing payment instruments to a person located in Colorado, selling or issuing stored value to a person located in Colorado, or receiving money for transmission from a person located in Colorado. The law also defines “monetary value” as a medium of exchange whether or not redeemable in money, and defines “receiving money for transmission” as receiving money or monetary value in the United States for transmission by electronic or other means.
The 2018 Division guidance stated that cryptocurrencies are not recognized as legal tender and that direct transmission of cryptocurrency between two consumers is not subject to licensure under the Act. It also stated that, for third-party transactions, the complete absence of fiat currency is not money transmission, while the presence of fiat currency during a transmission may be subject to licensure.
The same guidance identified a licensing trigger where a person is in the business of buying and selling cryptocurrency for fiat currency, a Colorado customer can transfer cryptocurrency to another customer within the exchange, and the exchange can transfer fiat currency through the medium of cryptocurrency. Because the guidance says it does not amend the Act and may be changed or withdrawn, it should be treated as regulator interpretation rather than a standalone statutory safe harbor.
Article 110 provides that a person may not engage in the business of money transmission, or advertise that it can provide money transmission, unless licensed under the article, an authorized delegate of a licensee, or otherwise exempt. The Banking Board may use NMLS and multistate licensing processes, and the Colorado Secretary of State lists 3 CCR 701-7 Money Transmitters as the current rule chapter effective August 6, 2025.
The MTMA also sets prudential requirements. Licensees must maintain tangible net worth, provide security through a surety bond or approved deposit, and maintain permissible investments at least equal to outstanding money transmission obligations. The statutory trust language is designed to protect purchasers and holders of outstanding obligations if a licensee becomes insolvent or enters a comparable proceeding.
HB25-1201 was introduced in the House on February 10, 2025, signed by the governor on April 18, 2025, and listed in the session laws as Chapter 91 with an August 6, 2025 effective date. Article 110 is scheduled for repeal on September 1, 2030, unless continued after review under Colorado’s sunset process. This profile is a legal-reference summary and does not provide legal advice.
A person may not engage in, advertise, solicit, or represent that it provides money transmission unless licensed, exempt, or acting as an authorized delegate.
The MTMA covers specified payment instruments, stored value, and receiving money or monetary value for transmission from persons in Colorado.
Division guidance says direct consumer-to-consumer crypto transfers are not licensed money transmission; fiat-linked third-party flows may be.
Licensees must maintain tangible net worth, security through a bond or approved deposit, and permissible investments covering outstanding obligations.
The Banking Board may use NMLS, coordinate with other regulators, adopt rules, and suspend or revoke licenses for listed violations.
Division guidance addressed when crypto-related activity may require a Colorado money transmitter license.
Colorado House introduced the Model Money Transmission Modernization Act bill.
The bill became law after gubernatorial signature.
Chapter 91 and current 3 CCR 701-7 rule version became effective.
Colorado Division of Banking, Colorado General Assembly, Colorado State Banking Board
Cryptocurrency, Virtual currency
This profile covers Colorado’s current Title 11, Article 110 money transmission framework plus the Division of Banking’s 2018 cryptocurrency guidance. Editors should verify whether the 2018 guidance remains operative after HB25-1201.
