We already covered why a Ruger 10/22 isn't a specified semiautomatic firearm despite some early rumors. The same question comes up for .22LR pistols — a Ruger Mark IV, a Browning Buckmark, a Smith & Wesson SW22 Victory — and it's worth answering directly, because there's a real mechanical wrinkle here that the rifle version of this question doesn't have.
The wrinkle: these pistols actually are "gas-operated" under the statute's own definition
Here's what makes this less obvious than the rifle case. Nearly every .22LR semiautomatic pistol cycles by straight blowback — the fired cartridge's pressure alone pushes the slide back, with no locking mechanism holding the breech closed the way a centerfire pistol needs. Colorado's statute defines a "gas-operated semiautomatic handgun" to include five specific methods, and the fifth one is: "a blowback-operated system that directly utilizes the expanding gasses of the ignited propellant powder acting on the cartridge case to drive the breechblock or breech bolt rearward." That's exactly what a .22 pistol does. Read in isolation, a Ruger Mark IV meets the "gas-operated" definition.
Why the rimfire exemption should still cover it
The rimfire exemption in 18-12-116(1)(d)(II)(A) excludes "a firearm designed to accept, and capable of operating only with, .22 or lower caliber rimfire ammunition" — full stop, unless the firearm has a separate upper and lower receiver. Nothing in that clause limits it to rifles; it says "firearm," and a .22LR pistol qualifies just as much as a .22LR rifle does.
The exception-to-the-exception — the separate-upper-and-lower clause — is written to catch AR-pattern .22 pistols and rifles, where the design genuinely mirrors the modular AR platform (a serialized lower paired with a separate, non-serialized upper). A Ruger Mark IV or Browning Buckmark isn't built that way. Even though the Mark IV has a distinctive two-part takedown design for cleaning, that's a barrel/receiver takedown joint, not a modular AR-style upper-and-lower receiver system — there's no separate serialized "upper" the way an AR-15 has one. We think that puts these pistols outside the separate-upper-and-lower exception and squarely inside the rimfire exemption, meaning the "gas-operated" question never has to be reached at all.
Where we'd stop short of certainty
We haven't found a court ruling, a Statement of Position, or a declaratory order that specifically addresses whether a takedown-style .22 pistol frame counts as having a "separate upper and lower receiver." This is genuinely a case where the statute's language was clearly written with AR-pattern platforms in mind, and a traditional .22 pistol design doesn't fit that mold — but "doesn't fit the mold we think lawmakers meant" isn't the same as a guaranteed legal conclusion.
Bottom line
A standard Ruger Mark-series pistol, Browning Buckmark, or similar traditional .22LR pistol design should fall under the rimfire exemption the same way a Ruger 10/22 does, despite technically operating by blowback. A dedicated .22LR AR-pattern pistol — built on an actual AR-style lower with a separate upper — is a different story and likely doesn't get the same protection. If you own something unusual that blurs that line, this is exactly the kind of question worth running through the state's Statement of Position process for a documented answer.
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