Colorado (CO)
Money transmission and virtual currency licensing planning data for Colorado.
Population weight (planning): 1.74% · Back to matrix · Launch map
How to read this page: confirmed cells are checked against a primary regulatory source and dated. Under review marks a cell where primary sources conflict or a figure awaits confirmation.
MTL required
Yes, because of the fiat ramp. The Money Transmission Modernization Act (effective 6 August 2025) licenses receiving money for transmission from a Colorado person, and the Division of Banking's own December 2025 interim guidance confirms this fiat leg triggers licensure regardless of the crypto side of the business.
Verified 2026-07-16. Source
Fiat treatment
Receiving money for transmission from a Colorado person is one of three licensed money transmission activities. C.R.S. 11-110-201(20)(a)(III).
Verified 2026-07-16. Source
Virtual currency treatment
Guidance-clarified carve-out, not a separate licence: the Division's December 2025 interim guidance concludes pure virtual currency transmission, no fiat leg, not a payment stablecoin, is not itself licensable; payment stablecoins count as stored value and need a licence unless the issuer is federally qualified under the GENIUS Act, which preempts the state requirement.
Verified 2026-07-16. Source
Regulator
Colorado Division of Banking, Department of Regulatory Agencies (DORA).
Verified 2026-07-16. Source
NMLS / portal
Money Transmitter License, filed through the Nationwide Multistate Licensing System.
Verified 2026-07-16. Source
Launch posture
amber: Brand-new MTMA regime with a helpful regulator carve-out for pure crypto-to-crypto activity, but this scenario's fiat ramp keeps it fully in scope, and payment-stablecoin handling adds.
Verified 2026-07-16. Source
Net worth / capital (locked)
Net worth / capital is included with access.Permissible investments (locked)
Permissible investments is included with access.Exam / audit timeline (locked)
Exam / audit timeline is included with access.Practitioner notes (locked)
Practitioner notes is included with access.Under the planning scenario
LicenceMap's bond and net worth figures use one scenario throughout: a virtual currency exchange with a fiat on and off ramp, $50m in annual US transmission volume, $2m in average daily outstanding liability, and a single principal office.
Surety bond: Surety bond is included with access.
Net worth / capital: Net worth / capital is included with access.