What the official sources support
Applicability and exclusions are shown with each finding. “Qualified” or “conflicting” findings are not simplified into an operational answer.
Authority, credentials, and scope
Regulator, governing authority, credential names, regulated titles, scope boundaries, exemptions, and prohibited activities.
Colorado behavior-analyst licensure is not current
Enacted, not operational · ConfirmedAs of August 11, 2026, Colorado does not yet issue the behavior-analyst and assistant-behavior-analyst licenses created by House Bill 26-1425.
- Applies to
- Use for Future Licensed Behavior Analyst, Future Licensed Assistant Behavior Analyst research in CO.
- Known exclusions
- A payer, facility, employer, local government, or another professional board may impose additional requirements.
- Effective date
- 2028-07-01
- Fact checked
- 2026-08-11
Application and practice status
Application, education, examination, background check, fees, temporary authority, endorsement, and supervised versus independent practice.
A future DORA licensing board was enacted
Enacted, not operational · ConfirmedHouse Bill 26-1425 creates the Colorado Behavior Analyst Licensing Board within DORA to implement and regulate the future licenses.
- Applies to
- Use for Future Licensed Behavior Analyst, Future Licensed Assistant Behavior Analyst research in CO.
- Known exclusions
- A payer, facility, employer, local government, or another professional board may impose additional requirements.
- Effective date
- 2028-07-01
- Fact checked
- 2026-08-11
Supervision and workforce evidence
Supervisor qualifications, written agreements, settings, hours, reporting, license verification, and hiring or credentialing evidence.
Mandatory practitioner licensure begins July 1, 2028
Enacted, not operational · ConfirmedBeginning July 1, 2028, a nonexempt individual may not engage in or offer applied behavior analysis without the license created by the act.
- Applies to
- Use for Future Licensed Behavior Analyst, Future Licensed Assistant Behavior Analyst research in CO.
- Known exclusions
- A payer, facility, employer, local government, or another professional board may impose additional requirements.
- Effective date
- 2028-07-01
- Fact checked
- 2026-08-11
Cross-border and practice structure
Telehealth location rules, registration, compact privileges, ownership, entity naming, fee sharing, and multidisciplinary practice.
Assistant behavior analysts will require supervision
Enacted, not operational · ConfirmedThe future assistant behavior analyst license requires practice under a licensed behavior analyst and within the scope established by Board rules.
- Applies to
- Use for Future Licensed Behavior Analyst, Future Licensed Assistant Behavior Analyst research in CO.
- Known exclusions
- A payer, facility, employer, local government, or another professional board may impose additional requirements.
- Effective date
- 2028-07-01
- Fact checked
- 2026-08-11
Client-facing operations and records
Disclosure, consent, telehealth, emergencies, advertising, confidentiality, access, retention, minors, subpoenas, closure, fees, billing, and termination.
Technician and temporary-certification rules are separate
Enacted, not operational · ConfirmedThe act distinguishes behavior technicians from the future licensed professions and directs Medicaid reimbursement treatment for certification and one temporary certification-pursuit period.
- Applies to
- Use for Future Licensed Behavior Analyst, Future Licensed Assistant Behavior Analyst research in CO.
- Known exclusions
- A payer, facility, employer, local government, or another professional board may impose additional requirements.
- Effective date
- No separate future date recorded
- Fact checked
- 2026-08-11
Maintenance, complaints, and monitoring
Renewal, continuing education, audits, inactive status, reinstatement, complaints, discipline, effective dates, exclusions, and unresolved interpretations.
ABA and day-treatment facility transitions have earlier dates
Published research · ConfirmedNewly captured day-treatment facilities were required to apply by August 1, 2026 and must be licensed by August 1, 2027; the act separately directs licensing standards for ABA clinics.
- Applies to
- Use for Future Licensed Behavior Analyst, Future Licensed Assistant Behavior Analyst research in CO.
- Known exclusions
- A payer, facility, employer, local government, or another professional board may impose additional requirements.
- Effective date
- 2026-08-01
- Fact checked
- 2026-08-11