We've seen the theory floated online: buy a stripped lower receiver from one place and an upper from another, never buy a "complete SSF" in one transaction, and skip the eligibility card and safety course entirely. The state's own published guidance says otherwise, in plain language.
What the guidance document says
The Firearms Dealer Division's official July 1, 2026 guidance states: "Under the plain language in sections 18-12-101(1)(j), (m), and (l) and 18-12-116(1)(d), C.R.S., frames or receivers for Specified Semiautomatic Firearms and weapons parts kits for Specified Semiautomatic Firearms are within the definition of Specified Semiautomatic Firearms and therefore subject to the requirements in section 18-12-116, C.R.S."
That's about as direct as agency guidance gets: a bare receiver — upper or lower — for a gun that would otherwise be an SSF is itself treated as an SSF. Same goes for a complete parts kit.
Why this isn't actually surprising
Colorado, like federal law, already treats the frame or receiver as legally equivalent to "the firearm" for most regulatory purposes — a stripped AR-15 lower has required an FFL transfer and background check for years, independent of anything in SB25-003. This new law just makes clear that the same logic carries over to the SSF-specific restrictions: if the receiver is destined to become (or is functionally configured as) part of a detachable-magazine semiautomatic rifle or shotgun, or a gas-operated detachable-magazine handgun, it doesn't matter whether you're buying it alone, as a kit, or as a finished gun.
The practical upshot
Splitting a purchase into an upper transaction and a lower transaction doesn't avoid the eligibility-card-and-course requirement after August 1, 2026, if what you're building is an SSF. This also closes off a workaround that would have otherwise made the entire law fairly easy to route around — which is presumably exactly why the Division wrote it this way.
We ran across this exact claim — that receivers wouldn't be regulated — attributed to comments at a stakeholder call, and it doesn't match the written guidance at all. When the two conflict, go with what's actually published.
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.
