Colorado Demographic Workforce Data Reporting
Colorado enacted a state-level demographic workforce data requirement in 2026. Beginning July 1, 2027, private entities doing business in Colorado that employ 100 or more workers must include federal EEO-1 demographic data in their periodic report filed with the Colorado Secretary of State.
Two things about this are widely misdescribed, so get them right:
It is not a pay data report. It covers demographic data - race, ethnicity, gender, job category. Not compensation.
It is not a standalone filing. The data goes into the entity's existing periodic report to the Secretary of State - a corporate filing, not a labour-department submission.
The essentials
| Legislation | HB26-1207, Disclosure of Demographic Workforce Data |
| Signed | June 4, 2026 |
| Act effective | August 12, 2026 |
| Reporting begins | July 1, 2027 |
| Who | Private entities doing business in Colorado employing 100 or more workers |
| What | Federal EEO-1 demographic data |
| Where | The entity's periodic report to the Secretary of State |
| Excluded | Government entities, schools, quasi-governmental bodies |
The provision that makes this durable
The obligation continues even if the federal requirement disappears. The act expressly requires an employer to provide the data "even if the federal government repeals or discontinues the federal requirement."
That is not a hypothetical. In July 2026 the federal agency published a proposal to rescind the EEO-1 entirely. Colorado's legislature wrote around exactly that possibility.
The practical consequence for employers: if the federal report is eliminated, Colorado employers must continue collecting and compiling EEO-1-format demographic data anyway, without a federal form or federal instructions to work from. Anyone planning to stop collecting demographic data if the federal requirement goes away should not do so if they operate in Colorado.
The separate transparency requirements
Colorado also has pay transparency obligations that are already in force and are often confused with the above. Different law, different scope:
- Applies to all employers with at least one Colorado employee. No size threshold.
- Every posting, internal and external, must include:
- Compensation - a rate or good-faith range. Open-ended ranges like "$30,000 and up" are non-compliant.
- Benefits - the general nature and scope of healthcare, retirement, paid time off and other tax-reportable benefits. Vague language such as "etc." or "and more" is non-compliant.
- Application details - how to apply and a good-faith estimated deadline. "Open until filled" is non-compliant.
- Job opportunity notice: employers must make reasonable efforts to announce each job opportunity to all employees on the same calendar day and before making a hiring decision.
- Post-selection notice: within 30 days of hiring, notify employees who regularly work with the new hire.
- Recordkeeping: job descriptions and compensation records for each employee, retained during employment plus two years after termination.
- Penalties: $500 to $10,000 per violation. Each job posted, or required to be posted and not posted, is one violation.
Enforcement is real rather than theoretical - as of August 2026 the state reported 24 citations and $841,500 in total fines, reduced to $482,450 after settlements, with a 78.89% cure rate on voluntary compliance letters.
Frequently asked questions
Is this a pay data report?
No. Demographic data only - race, ethnicity, gender, job category. Not compensation.
When does it start?
Reporting begins July 1, 2027.
Where do we file it?
In your periodic report to the Colorado Secretary of State. It isn't a standalone filing.
What if the federal EEO-1 is eliminated?
You must still provide the data. The act says so explicitly.
Does the transparency law have a size threshold?
No. It applies to any employer with at least one Colorado employee.
Can we post a range as "$30,000 and up"?
No. Open-ended ranges are non-compliant.
Can a posting say "open until filled"?
No. A good-faith estimated application deadline is required.
This guide is general information about reporting requirements, not legal advice. Verify current deadlines, thresholds and penalty amounts against the issuing agency before you file.