Proposed Colorado Law Creates a Gun Registry and Forces FFLs to Build It

Don’t blink, Colorado. Democrat gun-grabbers are down at the state capitol with even more gun control. HB26-1126 Requirements for Firearms Dealers, tacks additional regulations on to the new state-level firearm dealer regulatory system that has barely had time to operate.

This bill expands state power for its own sake, and in my opinion, the most consequential part of that expansion is the requirement of electronic tracking of lawful firearm transactions. But before I get to that, here’s a little background.

In 2024, the legislature passed HB24-1353, creating a brand-new state firearm dealer licensing program run by the Colorado Department of Revenue (DOR). Yes, the state taxing agency. I called this the “Colorado ATF” when we were battling it in the legislature. Then last year, HB25-1314, gave police powers to the agents hired by DOR to operate within their new Firearms Dealer Division. 

As of July 1, 2025, firearm dealers must:

• hold a state dealer permit in addition to their federal FFL,

• submit to DOR inspections,

• fingerprint employees,

• complete state-mandated training,

• comply with existing federal and new state recordkeeping laws,

• and more.

If this system just went live, what exactly are we fixing? There’s no answer, because there’s no problem.

Since the program began, there is no compliance data. No evidence of widespread violations (or any violations for that matter). No showing that existing recordkeeping is inadequate or that dealers are failing to follow the law.

But that didn’t stop state lawmakers from introducing their latest overreach in HB26-1126.

HB26-1126 dramatically expands what firearm dealers must record and how those records can be kept. Under the bill, dealers are required to maintain records for every firearm transaction: sales, transfers, rentals, and exchanges. This is in addition to the form 4473 required by the ATF.  This is nothing short of the creation of a state-level registry readily accessible by state agents. 

Each record must include, at minimum:

• the buyer’s name, age, and address

• detailed firearm information (make, model, caliber or finish, serial number or identifying mark)

• the date of the transaction

• the firearm dealer employee or responsible person involved

The bill then explicitly allows those records to be kept electronically. Electronic records are searchable, sortable, exportable, and easy to aggregate. Once firearm transaction data exists in digital form, it can be compiled across time, across dealers, and across locations with very little effort. And HB26-1126 places no limits on how that data can be retained, copied, or analyzed once accessed.

Going even further, HB26-1126 requires these records to be available “at all times” for inspection by peace officers and by state inspectors enforcing the dealer permit program.

Both federal law and Colorado law prohibit firearm registries. Lawmakers know this, which is why the word never appears in the bill.

But registries are defined by function, not labels. When every transaction is logged, when the data is digital, when the government has routine access, and when there are no limits on aggregation or retention, the result is the same regardless of what lawmakers call it. This bill builds that system step by step.

Put plainly, the state wants a system where:

• firearm dealers must keep detailed, digital transaction records

• a regulatory agency with law-enforcement powers can routinely access them

• there are no statutory limits on aggregation or retention

Claims that firearm transaction records are “already tracked” under federal law ignore how limited access to ATF Form 4473 actually is. A 4473 is a dealer-held record, not a government database. While ATF may review forms during narrowly limited compliance inspections or as part of a specific criminal investigation, federal law explicitly prohibits ATF from creating or maintaining a firearm registry or aggregating records into a searchable ownership database. State agencies do not have routine or independent access to 4473s, and records remain decentralized and under dealer control while a business is operating. HB26-1126 departs from that model by expanding state-mandated firearm transaction records, explicitly allowing electronic storage, and granting ongoing access to state inspectors and peace officers, replacing a tightly constrained federal system with a state-level framework that removes the guardrails entirely.

HB26-1126 doesn’t stop at data collection. It also mandates new, statutory security requirements for firearm dealers that go well beyond existing federal guidance and insurance standards. Beginning October 1, 2027, dealers would be required to install alarm systems and video surveillance covering every exterior door and all areas where firearms are stored. Those systems must either be directly connected to a law enforcement agency or continuously monitored by a third-party security service.

Gun stores already invest heavily in security, not only at the direction of insurers and the ATF, but because no one cares about their business as much as they do. What this bill does is hard-code law enforcement integration into the daily operation of lawful businesses, blurring the line between private commerce and state surveillance. And, like the rest of this bill, it comes with no evidence of a problem and no explanation for why existing security standards suddenly aren’t enough.

The bill also adds new requirements for how dealers must store so-called “large-capacity magazines”, including locked displays or secured rooms. There’s just one problem: large-capacity magazines have been illegal to sell in Colorado since 2013. So what is this section actually regulating? 

Digging deeper, the bill includes draconian enforcement provisions and penalties. Beginning in 2027, a second or subsequent violation allows DOR to impose fines of up to $100,000, suspend a dealer’s state permit, or revoke it entirely. This for compliance failures tied to paperwork, process, and data handling now tied to complex electronic systems and constant inspection authority. At this point, they aren’t even pretending. This is regulatory pressure by design, intended to make operating a gun store increasingly risky until fewer of them remain. The fines collected would go back into the funding of the Firearms Dealer Division of DOR, creating an incentive to find potential offenses.