By: Jeffrey Backman, Esq. ,Roy Taub, Esq. and Jacob Mars, Esq.
Colorado’s Senate Bill 26-174 creates a new compliance concern for businesses that generate legal-service leads through telephone calls, text messages, websites, and other marketing channels. The law adds C.R.S. § 6-1-741 to the Colorado Consumer Protection Act (“CCPA”) and targets certain forms of “lead generation legal marketing.” The bill was signed by Governor Jared Polis on June 3, 2026, and goes into effect on August 12, 2026.
The new law addresses an issue different than that of the Telephone Consumer Protection Act (“TCPA”) and other more familiar telemarketing regulations: how the consumer’s information was obtained in the first place. Under C.R.S. § 6-1-741, certain lead-generation practices involving attorneys and law firms are now prohibited. The statute targets arrangements in which a person receives compensation for providing information about prospective legal clients, including through direct or indirect payments, per-lead arrangements, subscriptions, intermediaries, and affiliates. The statute also addresses deceptive practices, including advertising that may cause consumers to believe they are communicating with a particular attorney or law firm when they are actually interacting with a third-party lead generator.
For those familiar with the TCPA and the navigation of those minefields, this distinction is important. A business may have evidence that a consumer consented to receive calls or texts, but that consent does not necessarily resolve whether the underlying lead was generated or transferred lawfully under this new Colorado law. The new law makes the source of the lead and the representations made to the consumer potentially significant additional considerations.
For example, if a consumer submits information believing they are contacting a specific law firm, but the information is actually collected by a third-party lead generator and sold to multiple law firms, questions may arise concerning both the validity and scope of the consumer’s consent and whether the lead-generation arrangement complies with C.R.S. § 6-1-741.
Additionally, the obligation to comply with C.R.S. § 6-1-741 is not simply limited to lead generators. Purchasers of leads, including law firms, may also face liability. C.R.S. § 6-1-741(3) states that, unless a person meets the criteria described in subsection (4),[1] a person shall not:
- Pay money or other compensation for lead-generation legal marketing services in Colorado;
- Engage in lead-generation legal marketing in Colorado; or
- Sell leads to an attorney, law firm, or licensed legal paraprofessional in Colorado.
That first prohibition is particularly important because it appears to place liability on the purchaser of the lead.
C.R.S. § 6-1-741 authorizes affected attorneys, law firms, licensed legal professionals, and consumers and certain legal professionals to bring civil actions. A prevailing claimant may recover $10,000 per violation, along with reasonable attorneys’ fees and costs, and courts may award injunctive relief. That remedy would likely be separate from other telemarketing statutes upon which claims are generally brought, such as the TCPA, which generally provides up to $500 per violation and potentially $1,500 if the violation is found to be willful or knowing.
[1] A person may solicit a potential client or market for legal services in the state if the person is:
(a) Authorized by the Colorado Supreme Court to practice law in the state;
(b) Working on behalf of a person authorized by the Colorado Supreme Court to practice law in the state, and the person who is authorized to practice law in the state or the law firm or business for which the person works is clearly identified in any advertisement, marketing material, information, or resources; or
(c) A nonprofit organization that engages in legal services in the state.
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