Colorado · SB25-003

The Loophole They Wrote Themselves

Want to skip the SB25-003 card, skip the class, and still take home the same firepower they told you needed a permission slip?

Here are the “workarounds” — courtesy of the people who wrote the law.

Confused? Start here · The customer journey

Before you pick a class, know the steps

If you do want one of the gated rifles, SB25-003 makes you complete a sequence of state steps before a course even counts. Don’t guess — read Colorado’s own official walkthrough of exactly what’s required and in what order.

The Official Customer Journey →

Understand what the Capitol actually did: they set out to put gas-operated, magazine-fed semiautomatic rifles behind a sheriff’s card, state fees, and hours in a state-approved classroom — and then they blinked. Right there in the statute, in black and white at C.R.S. § 18-12-116(1)(d)(II)(E), they wrote themselves a list of rifles the law doesn’t touch. The Ruger Mini-14 Ranch Rifle. The Ruger Mini Thirty. The M1 Carbine. No card. No class. No waiting for a seat in a course they made scarce. Walk in, pass the same background check as always, walk out.

The statute’s own exemption · C.R.S. § 18-12-116(1)(d)(II)(E)
Semiautomatic. Detachable magazine. Gas-operated. And exempt — by name.
  • Ruger Mini-14 Ranch Rifle5.56 NATO / .223 — same round as the AR-15 they gated
  • Ruger Mini Thirty7.62×39 — same round as an AK
  • M1 Carbine.30 Carbine — 15-rd G.I. mags legal in the box

And here’s the part that should make you smile: these rifles do everything the gated ones do. The Mini-14 runs the same 5.56/.223 as the AR-15 they gated. The Mini Thirty feeds the same 7.62×39 as an AK. The M1 Carbine — the rifle that armed more American troops in WWII than any other — is a light, fast, .30-caliber semiautomatic whose 15-round G.I. magazines are Colorado-legal in the box. Same gas operation. Same detachable magazines. Same capability, minus the paperwork. The only real difference between a Mini-14 and an AR-15 is that one wears walnut and the other wears black — and the law’s own authors decided that’s what matters. They didn’t regulate function. They regulated looks.

So every one of these rifles sold is a completely legal, background-checked, statute-blessed reminder that the law doesn’t do what they said it does — and there is nothing they can do about it, because they wrote the exemption themselves.

Buy the rifle they forgot to fear.
That’s not breaking the law. That’s beating it.

Two More Doors They Left Wide Open

Those three rifles are just the start. The statute’s definition of a “specified semiautomatic firearm” carves out its own exceptions at C.R.S. § 18-12-116(1)(d)(II) — and two of them hand ordinary buyers a gas-operated, magazine-fed semiautomatic rifle with no card and no class.

Door one — the named list, subsection (E). The legislature didn’t exempt three rifles; it exempted dozens, “as they exist and are configured on the effective date.” The list is full of gas-operated, detachable-magazine rifles that would otherwise be gated — carved out by name:

Exempt by name · C.R.S. § 18-12-116(1)(d)(II)(E)
  • Springfield Armory M1Athe civilian M14 — gas-operated, 20-rd detachable box mag
  • Browning BAR (Mk 3 & others)gas-operated hunting semi-auto, detachable mag
  • Remington 7400 / 750 / 740 / 742gas-operated, detachable mag
  • FN49 · SVT-40 · Gewehr 43 · Ljungman AG42the classic service semi-autos, named outright
  • Ruger Mini-14 · Mini Thirty · M1 Carbineplus Winchester 100, Valmet Hunter, VZ.52 & more

Door two — old enough to be exempt, subsection (G). The law also excludes an antique firearm (18 U.S.C. § 921(a)(16)) or a curio or relic (27 CFR 478.11). The antique prong is the pre-1899 rule — irrelevant to modern rifles — but the curio-and-relic prong is pure arithmetic: any firearm manufactured at least 50 years ago is automatically a C&R (a rolling date — as of 2026, made in 1976 or earlier), alongside the models on the ATF’s published C&R list. That catch-all reaches the guns the named list doesn’t mention — including the one they most wanted to gate:

Card-free by age · C.R.S. § 18-12-116(1)(d)(II)(G)
  • Colt AR-15 / SP1 (vintage)the original AR — the earliest SP1s (1964–1976) are now 50+ years old
  • Milled-receiver AK / Chinese Type 56vintage gas-operated, detachable-mag — C&R by age

They gated the black rifle
and exempted the old one.

Read the fence carefully · so you buy right, not wrong

The named exemption is frozen to each model “as configured on the effective date” — modify it and you can lose it. The C&R exemption attaches to the individual firearm, not the model name: a brand-new AR-15 is not a curio or relic, but a genuinely vintage one (50+ years old, or ATF-listed) is — new-production reissues never qualify by age. And two limits still apply no matter how old the rifle is: full-auto is still a National Firearms Act matter — age doesn’t unlock it, and the 1986 registry closure means only pre-’86 registered guns transfer, at collector prices — and Colorado’s 15-round magazine cap still governs the magazines you feed it. These doors get you the rifle without the card; they do not get you a machine gun or a 30-round mag. Verify a specific gun’s status before you buy: the exemptions live in SB25-003 itself, the C&R definition in 27 CFR § 478.11, and the current ATF Curios & Relics list.

The Ranch Rifle Play · Same Rifle, Tactical Dress

Here’s the named exemption at its most practical. SB25-003 is not a cosmetic-features ban — nowhere does it prohibit a pistol grip, a folding or adjustable stock, a threaded barrel, a flash hider, or a rail. It gates a mechanism (gas-operated semi-auto, detachable magazine) and then exempts specific models. The Ruger Mini-14 Ranch Rifle is one of them, by name. So start with what the statute blesses — and change its clothes.

  1. Buy the Ruger Mini-14 Ranch Rifle. Named-exempt at § 18-12-116(1)(d)(II)(E) — no card, no class, the same background check as always.
  2. Drop it into a tactical chassis. Folding or collapsible stock, pistol grip, free-float handguard with M-LOK rails — aftermarket kits do this bolt-on.
  3. Dress it out. Optic, light, sling, muzzle device. None of it is a prohibited feature under SB25-003 — the statute has no feature list to violate.
  4. Keep the barrel 16″ or longer. Go shorter and you’ve built a federal Short-Barreled Rifle — an NFA item with its own federal tax-stamp process. Age and state exemptions don’t touch that.
  5. Feed it 15-round magazines. The rifle is exempt; Colorado’s magazine cap still applies to what you load it with.

The result is a rifle that looks every bit as “tactical” as the AR they gated — the same capability it always had — built on a receiver the legislature itself put on the exempt list. You changed how it looks, not what it is or how it works.

They banned the costume, not the rifle.
So change the costume.

The honest fence · two cautions before you build

One: the named exemption reads “as they exist and are configured on the effective date.” The better-reasoned view is that this snapshots which factory models are exempt — so makers can’t bolt new guns onto the list — not that it polices a private owner’s stock swap; the mechanism and the model don’t change when you change furniture. But it’s untested in court, so confirm current state guidance or counsel before you build. Two: local ordinances can be stricter than the state. SB25-003 has no feature test, but a city might — Denver has its own features-based ordinance (now under DOJ challenge) — so check your locality, not just the statute.

Example Builds · Same Lethality, Different Legality

Here’s the exhibit that settles the intent question. Below are three ways to own a .223 / 5.56 semi-automatic with 15 rounds — the exact caliber and capacity Colorado already lets every citizen carry. Each is legal under SB25-003. Each is as capable as the AR-15 the law bans. The only thing that changes between “legal” and “banned” is the model on the receiver, the age of the gun, or how the magazine attaches — never the lethality. A safety law would track danger. This one tracks SKUs.

Build A · The Fixed-Magazine AR-15

Exempt via C.R.S. § 18-12-116(1)(d)(II)(C) — permanently fixed ≤15-round magazine

Parts: a standard AR-15 lower and upper, .223/5.56, 16″ barrel, and any furniture you like — pistol grip, adjustable stock, free-float rail, optic. Conversion: a fixed-magazine kit that makes the magazine permanently non-detachable and caps it at 15 rounds; you reload through the action, not by dropping a mag. Result: the same rifle, same caliber, the same 15 rounds Colorado already permits — the only thing the law changed is how fast you reload. The statute carves this out in so many words: a semi-auto “converted to have a permanently fixed magazine that cannot accept more than fifteen rounds.”

Build B · The Mini-14 Tactical — with detachable mags

Exempt via C.R.S. § 18-12-116(1)(d)(II)(E) — named model

Parts: a Ruger Mini-14 Ranch Rifle, .223/5.56, fed by detachable 15-round magazines. You don’t even need an aftermarket chassis — Ruger sells the Ranch in a factory black synthetic stock, on the shelf at major retailers (Bass Pro Shops stocks it), so it leaves the store already wearing the black-rifle look. Drop it in a tactical chassis and it’s indistinguishable at a glance. Result: a tactical .223 semi-auto with detachable magazines — more convenient than the fixed-mag AR above — and fully legal, because the rifle wears the name “Mini-14.” Read that twice: the law bans a detachable-mag AR but blesses a detachable-mag Mini-14 of identical caliber and capacity. The difference isn’t function. It’s the rollmark.

Build C · The Vintage Colt SP1 — the actual AR

Exempt via C.R.S. § 18-12-116(1)(d)(II)(G) — curio & relic, 50-year rule

Parts: a pre-1976 Colt AR-15 / SP1 — the original AR platform — with detachable 15-round magazines. Result: the actual AR-15, detachable mags and all, card-free — solely because it’s old enough to be a collectible. Same design, same caliber, same magazine; legal because of a birthday.

Three legal paths to the same 15-round .223.
One banned path to the same 15-round .223. If capability were the concern, they’d all be treated alike.

Who this actually hits

Notice what these builds prove about the target. The capability never leaves the market — you can still get a 15-round .223 semi-auto three different ways. What SB25-003 removes from the shelf is a set of SKUs: the modern, detachable-magazine AR- and AK-pattern rifles an FFL already bought and stocked in good faith. Overnight, that inventory becomes unsellable dead capital — while the functionally identical Mini-14 beside it sells fine. A law aimed at danger would restrict the capability. A law aimed at inventory restricts the label — and it’s Colorado’s gun shops, holding lawful stock they can no longer move, who pay for the distinction.

Build it right, or don’t build it

These are lawful-configuration examples, not a shortcut around anything: every purchase still runs the same background check, for eligible people and licensed dealers acting in good faith. Get the details exactly right. The fixed magazine must genuinely be permanently fixed to meet subsection (C) — a normal detachable 15-rounder does not qualify. Keep every barrel 16″ or longer or you’ve built a federal Short-Barreled Rifle (NFA). The 15-round cap applies to all of these. And SB25-003 is new and untested, with local ordinances (Denver) that can be stricter — so confirm current state guidance and counsel before you build or sell.

The List They Walked Back · Flagged, Then Handed Back

The state publishes a guidance list of the specific models it considers gated. Its May 15, 2026 draft swept in guns the statute never reached — and by the July 1 final, the Department of Revenue had quietly dropped them. Here’s what they flagged as “banned,” then had to hand back. You can diff the two documents yourself at the bottom of this section.

“Gas-operated”? Not quite — the blowback pistols

Handgun gate reaches only gas-operated pistols — § 18-12-116(1)(d)(I)(B)

The draft flagged the Walther CCP — its SoftCoil action is gas-delayed blowback, close enough to trip a first pass — then the final conceded it isn’t the gas-operated action the statute names. Struck alongside it: the HK VP70, the Ruger PC Charger, and the KelTec PR-5.7 — all blowback. The handgun ban only reaches pistols that vent gas to cycle the action; these don’t, so the state dropped them.

The AR that’s legal because it’s a .22

Rimfire excluded unless separate upper & lower — § 18-12-116(1)(d)(II)(A)

The draft swept in a shelf of .22 LR plinkers that look exactly like the guns it bans — Mossberg 715T, Walther’s licensed HK G36 / HK416 .22, ISSC MK22, KelTec SU22, Ruger’s tactical 10/22, Excel MR-22, Chiappa’s M1-22. Rimfire firearms are excluded unless they have a separate upper and lower receiver — so a .22 dressed as an AR-15 or an HK is legal, as long as its receiver is one piece. (A .22 built on a true separate-upper/lower AR stays gated — check the receiver.)

When the ban list catches a bolt gun

Manually operated firearms excluded — § 18-12-116(1)(d)(II)(B)

The draft listed Q’s “The Fix” and “Mini Fix” — bolt-action rifles — and the Rock Island VRPA40, a pump-action shotgun, as “specified semiautomatic firearms.” Both were struck from the final. And two of the Ruger and 10/22 entries carried the agency’s own uncertainty markers — ???? and *** — right on the draft. When your ban list flags a bolt-action, the problem isn’t the guns.

It took two drafts to stop banning bolt-action rifles.
That’s not a safety category. That’s a guess.

How to read this · and how to verify

These are guns the state’s own guidance moved off the ban list between its May 15 draft and its July 1 final — diff the two documents below and see for yourself. But guidance “does not constitute final agency action” (the documents say exactly that) and can change again; the rimfire exclusion carries the separate-upper/lower exception; and blowback-vs-gas can be a fine technical line (the CCP is gas-delayed blowback). The 15-round cap, NFA rules, and local ordinances still apply. Confirm any specific gun against the current guidance and the statute before you buy.

What SB25-003 Is Really Engineered to Do

Look past the language about safety courses and eligibility cards, and ask what SB25-003 actually does. It doesn’t ban a single rifle — it strangles the market that supplies them. Every AR-15 on a dealer’s shelf now sits behind a wall the customer must climb: a sheriff’s application, up to $177 in fees, hours of mandatory classroom time in courses the state made scarce, weeks of waiting. Most walk-in buyers walk back out.

The dealer’s inventory freezes into dead capital, and a shop that can’t turn inventory doesn’t order more — it stops stocking these rifles, then it shrinks, and some will simply close. That’s not a side effect; that’s the design. What this law is engineered to produce is a Colorado where the shops that sell these rifles no longer exist to sell them — where the right to acquire an ordinary self-defense rifle is never formally repealed but becomes practically unreachable, one closed FFL at a time. And the people it disarms are, by definition, the ones who follow the law: the peaceable citizen who fills out the form and waits is burdened at every step, while the criminal who does neither is untouched.

If the legislature wanted trained gun owners,
it would have funded courses instead of throttling them.

A law that only the law-abiding can violate is not a safety measure. It’s a slow-motion ban with the receipts hidden in the paperwork.

The Gauntlet · How It Infringes

If the excise tax is a toll, SB25-003 is a gauntlet — and each stage independently hinders. Before a Coloradan may buy the most commonly owned rifles in the country, the state requires, in order:

  1. Apply to a sheriff. Permission-seeking as a precondition to exercising a right.
  2. Pay $52, plus up to $125 in fees. A cost barrier stacked on the purchase itself.
  3. Pass a background check just to become eligible to take the class. A check before the check.
  4. Complete hours of mandatory in-person instruction — from an instructor pool the state itself constrains. A scarcity barrier.
  5. Wait a multi-week timeline. Delay, by design.
  6. Carry a card that expires in five years. Recurring submission to keep the right alive.

Any one of these, alone, might survive as a “condition on commercial sale.” The infringement argument is cumulative: stack them and the state has converted “shall not be infringed” into “may exercise upon completing our process, paying our fees, and waiting our timeline” — which inverts the right into a privilege. That is precisely the abuse Bruen’s footnote anticipated when it warned that even permissible licensing schemes become unconstitutional through “lengthy wait times” and “exorbitant fees.” And the plaintiffs have a live factual kicker: they allege the course infrastructure barely exists — the state built a mandatory doorway and then failed to hang the door. A right you must wait indefinitely to exercise is, during the wait, a right denied. See what “infringe” means →

For fairness · the strongest version of their case

Your readers will meet it in the wild, so meet it first: the law’s defenders say the purpose is exactly what’s on the label — that training requirements reduce accidents and impulsive violence, that Colorado modeled this on hunter education (which nobody calls a hunting ban), and that the carve-outs and course pathway show the legislature preserved access rather than choking it. The rebuttal is already above: scarcity of seats plus fee-stacking is a strange way to encourage training. If they wanted trained owners, they’d have funded the courses — not throttled them.

Read It Yourself · The Official Record
The Lawsuit · Del Toro v. Polis

Coloradans aren’t waiting quietly. In Del Toro v. Polis (No. 1:25-cv-02725, D. Colo., Judge William J. Martínez), the Colorado State Shooting Association and five of its members — represented by Mountain States Legal Foundation — are challenging SB25-003 in federal court, arguing the card-fee-course gauntlet collides head-on with the Second Amendment and the Supreme Court’s Bruen standard. Don’t take anyone’s word for it: read the filings and follow the docket yourself.

Case update · Aug 11–12, 2026 · Injunction motion filed, NRA joins

Ten days after the law took effect, the plaintiffs moved for a preliminary injunction (Aug 11, 2026) asking the court to halt the permit-to-purchase scheme while the case proceeds. The motion argues SB25-003 “does not merely regulate law-abiding citizens’ right to purchase these firearms—it all but eliminates it,” and it comes with 17 sworn declarations — including from Teller County Sheriff Jason Mikesell and Custer County Sheriff Lloyd Rich Smith. The evidence of collapse on the ground: fewer than 20 of Colorado’s 64 counties had a working application process, at least 21 counties had no approved trainer for the mandatory course, and Montezuma County’s sheriff declined to participate at all, citing resources. The next day, the NRA formally joined the fight — NRA-ILA counsel entered as co-counsel alongside MSLF and First & Fourteenth PLLC. No hearing date has been set on the injunction; the law remains in effect.

Case update · Sept. 1–8, 2026 · The state answers the injunction motion

On September 1 the state defendants (Polis, Weiser, and CPW director Clellan) filed their opposition to the preliminary injunction, with declarations from CPW and five expert reports; DA Allen filed separately. The state’s core argument is not that the burden is small — it is that the covered rifles “are not arms protected by the Second Amendment” at all. Its filing also put numbers on the rollout for the first time: in August, more than 3,500 people applied for an eligibility card, 1,125 cards were issued by 39 sheriff’s offices, and 502 people completed a course and exam (409 basic, 93 extended), with 330 instructors registered. CSSA’s response: “That’s a 14% completion rate.” On September 8 Judge Martínez allowed Brady and Giffords to file an amicus brief for the state; plaintiffs may respond by September 21. No hearing is set. (Rollout figures are from the CPW declaration as reported by Colorado Newsline, Sept. 11.)

Get Trained · Colorado Classes & Resources

Defend the win. Join the fight.

Loopholes are a smile; repeal is a mission. The Colorado State Shooting Association is carrying this fight in the Capitol and the courts. Add your name and your support — because a right defended by many is a right that endures.

Not legal advice · I am not a lawyer · Read the law for yourself

The author of this site is not an attorney and does not practice law. Nothing published here is legal advice, no part of it is offered as legal advice, and reading it creates no attorney-client relationship with anyone. This is Second Amendment advocacy and general-interest commentary written by a private citizen, and it includes opinion.

Full terms: Legal Notice & Terms of Use → Page last reviewed September 11, 2026. The law may have changed since.