Colorado's guidance list is long, but it isn't the final word — and the state built a formal process for resolving disagreements about it, right into the same document.
The document says so directly
The guidance's closing section states: "This guidance document does not constitute final agency action. Please consult Rule 1-200, 1 CCR 214-1 of the Colorado Firearms Dealer Rules, outlining the process and requirements for obtaining a Statement of Position from the Division, and, if a petitioner is dissatisfied with a Statement of Position from the Division, a declaratory order from the Executive Director of the Department of Revenue. A declaratory order constitutes final agency action subject to judicial review pursuant to section 24-4-105(11), C.R.S."
That's a two-step administrative process, with a court appeal available at the end if you still disagree.
Step 1: Request a Statement of Position
This is a formal written request to the Firearms Dealer Division asking whether a specific firearm — described by make, model, and configuration — is or isn't a specified semiautomatic firearm under 18-12-116. This is the right first move for a custom build, an unusual or discontinued model, or anything not clearly represented on the published list.
Step 2: Petition for a declaratory order
If you disagree with the Division's Statement of Position, you can petition the Executive Director of the Department of Revenue for a declaratory order. Unlike a Statement of Position, a declaratory order is "final agency action" — meaning it carries more legal weight and can actually be appealed to the courts.
Step 3: Judicial review
If you still disagree after a declaratory order, Colorado's Administrative Procedure Act (24-4-105(11)) gives you the right to seek judicial review in court.
Who this is actually useful for
FFL dealers with ambiguous inventory who want certainty before they sell something, builders with a custom or mixed-parts configuration, importers or small manufacturers introducing a new model, and individual owners of an unusual firearm who want a documented answer rather than a guess. This is a genuine regulatory process with its own timeline, not an instant email reply — if you're weighing a purchase or a build around the answer, start the process well before you need it.
As always, we are not lawyers — just Colorado citizens trying to understand the new law and share what we learn. The information on this website is for general informational purposes only and does not constitute legal advice, nor does it create an attorney/client relationship. The accuracy, completeness, or currency of the content is not warranted. Your use of content on this website is at your own risk. Consult an attorney about your specific circumstances.
