These Firearms May Not Appear on Colorado’s DOR List — But They Can Still Fall Under SB25-003

Colorado’s new Specified Semiautomatic Firearms law took effect August 1, 2026, and there is an important issue firearm buyers need to understand:

The Colorado Department of Revenue’s firearms list is NOT a complete list of every firearm that requires a Firearms Safety Course Eligibility Card.

So what about firearms that aren’t on the list at all?

That’s what we’re covering here..

Guns Not on the DOR List Can Still Require the Card

The DOR list identifies numerous makes and models that Colorado considers Specified Semiautomatic Firearms.

But Colorado’s law doesn’t say a firearm has to appear on that list before the Eligibility Card requirement applies.

Instead, the law generally covers:

Semiautomatic rifles with detachable magazines
Semiautomatic shotguns with detachable magazines
Gas-operated semiautomatic handguns with detachable magazines

There are statutory exemptions, but if a firearm meets the definition and isn’t exempt, its absence from the DOR list does not automatically get it around the law.

View Colorado’s Current Firearms List

Before purchasing a firearm, check the latest version directly from the Colorado Department of Revenue.

VIEW THE COLORADO DOR FIREARMS LIST

What Types of Guns May Be Missing From the List?

This is where Colorado firearm buyers need to pay attention.

There are far more semiautomatic firearms on the market than the state can reasonably identify individually.

AR-15 Rifles From Manufacturers Not Listed

There are dozens—if not hundreds—of companies manufacturing AR-pattern rifles and receivers.

If an AR-style semiautomatic rifle accepts a detachable magazine and otherwise meets Colorado’s definition, the fact that its particular manufacturer or model isn’t named on the current DOR list doesn’t automatically exempt it.

This can be especially relevant with:

Smaller AR manufacturers
Custom-built AR rifles
New AR models
Discontinued models
Less-common manufacturers
Older rifles and configurations

The manufacturer’s name isn’t what controls whether the firearm meets the statutory definition.

AK-Pattern Rifles Not Listed

The same issue exists with AK-pattern firearms.

There are numerous manufacturers, importers and variants of AK-style rifles. A particular AK may not appear by name on Colorado’s current list but still have the characteristics of a Specified Semiautomatic Firearm.

Pistol-Caliber Carbines

Pistol-caliber carbines are another category buyers should watch.

A semiautomatic rifle doesn’t become exempt simply because it fires 9mm, .40 S&W, .45 ACP or another traditional handgun cartridge.

If it is legally a semiautomatic rifle, accepts a detachable magazine and doesn’t qualify for an exemption, it may still fall under the law even when the exact model isn’t on the DOR list.

Newly Released Semiautomatic Rifles

This may be the clearest example of why the DOR list cannot be treated as complete.

Firearm manufacturers release new models every year.

A manufacturer could introduce a new detachable-magazine semiautomatic rifle after the DOR publishes its current guidance.

That firearm doesn’t suddenly become exempt while Colorado waits to update a PDF.

CPW specifically says that newly manufactured firearms meeting the criteria may be added to the guidance after the state conducts additional research.

Detachable-Magazine Semiautomatic Shotguns

The same applies to shotguns.

A semiautomatic shotgun that accepts a detachable magazine may fall within Colorado’s definition even if the particular make and model isn’t currently identified on the state’s list.

Some Firearms Are Specifically Exempt

Colorado law also contains several exclusions, including certain manually operated firearms, qualifying rimfire firearms, qualifying fixed-magazine firearms and recoil-operated semiautomatic handguns.

The law also specifically excludes certain firearm models, including examples such as:

AG42 Ljungman, Benelli Argo E Pro, Benelli R1 Big-Game Rifle, Browning BAR LongTrac Rifle, Browning BAR MK 3, Browning BAR ShortTrac Rifle, Fabrique Nationale Model 49 (FN49), Fusil Automatique Modèle 1917 (RSC M1917), Gewehr 43, Globco Mohawk, Hakim Rifle, HK SL6, HK SL7, M1 Carbine, M1941 Johnson Rifle, Marlin Camp Carbine, MAS49, Remington Model 4, Remington Model 8, Remington Model 740, Remington Model 742, Remington Model 750, Remington 7400, Ruger Deerfield Carbine, Ruger Mini-14 Ranch Rifle, Ruger Mini Thirty Rifle, Ruger Model 44, Springfield Armory M1A Standard Issue Rifle, SVT-40, Valmet Hunter M88, VZ.52, Winchester Model 100, Winchester Model 1905, Winchester Model 1907, Winchester Model 1910.

These statutory exemptions are different from a firearm simply being absent from the DOR list.

Not on the List Does NOT Mean Exempt

This is the biggest takeaway.

There is a major difference between:

A firearm that isn’t currently listed by the DOR

and

A firearm that is actually exempt under Colorado law.

Those are not the same thing.

Colorado specifically exempts certain firearm types, operating systems and models. Those exemptions come from the law itself.

Simply searching the DOR list and failing to find your gun is not an exemption.

What About Regular Handguns?

Most conventional recoil-operated semiautomatic handguns are a different story.

Colorado’s definition specifically addresses gas-operated semiautomatic handguns with detachable magazines and provides an exclusion for qualifying recoil-operated semiautomatic handguns.

That means your typical recoil-operated Glock, SIG Sauer, Smith & Wesson, HK or Springfield pistol generally isn’t subject to the Eligibility Card requirement merely because it is semiautomatic.

This distinction is important because the new law does not apply to every semiautomatic handgun sold in Colorado.

What Should You Do If Your Gun Isn’t Listed?

If you’re looking at purchasing a semiautomatic firearm and can’t find it on Colorado’s DOR list, don’t automatically assume you’re in the clear.

Determine whether the firearm itself meets Colorado’s definition of a Specified Semiautomatic Firearm.

Colorado Parks and Wildlife specifically states that if you need to determine whether a particular firearm is an SSF, you may petition the Colorado Department of Revenue Firearms Dealer Division for a statement of position.

That’s the safest route for unusual, uncommon or questionable firearm configurations.

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4 Hour Basic Firearms Safety Course

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If my gun isn’t on Colorado’s DOR list, do I need the Eligibility Card?

Potentially, yes. CPW specifically says the firearms guidance is not all-inclusive. If the firearm meets Colorado’s definition of a Specified Semiautomatic Firearm and isn’t exempt, it can still fall under the requirements.

What about an AR-15 manufacturer that isn’t listed?

An AR-pattern rifle isn’t automatically exempt because its manufacturer isn’t named on the DOR list. The firearm’s actual characteristics and configuration matter.

Are custom-built AR-15s automatically exempt?

No. A custom firearm isn’t automatically exempt simply because there isn’t an exact factory model for Colorado to place on its list.

What about new guns released after the list was published?

They can still potentially be covered. CPW specifically states that new firearms meeting the criteria may be added to the guidance after research and industry/public feedback.

Is every semiautomatic handgun covered?

No. Colorado’s handgun provision concerns gas-operated semiautomatic handguns with detachable magazines. Qualifying recoil-operated semiautomatic handguns are excluded.

Where can I find Colorado’s official list?

Use the Colorado Department of Revenue Firearms Dealer Division’s current Specified Semiautomatic Firearms Guidance.

Bottom Line

Colorado’s DOR list is not the complete universe of firearms that require a Firearms Safety Course Eligibility Card.

AR-pattern rifles, AK-pattern rifles, pistol-caliber carbines, detachable-magazine semiautomatic shotguns, newly released firearms and other models not specifically named on the current list can still fall under SB25-003 if they meet Colorado’s statutory definition.

Don’t confuse “not on the list” with “exempt.”

If you need the Eligibility Card, US Firearms Training Academy offers both the 4-hour and 12-hour Colorado Firearms Safety Courses in the Denver metro area.

VIEW UPCOMING FIREARMS SAFETY COURSES

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Legal Disclaimer

Legal Disclaimer: This information is provided for informational purposes only and does not constitute legal advice. Firearm laws can change, and local, state, federal, tribal, and municipal regulations may vary. Always verify current laws and consult a qualified attorney before carrying a firearm or making legal decisions related to self-defense. US Firearms Training Academy assumes no liability for actions taken based on this content.

Guns NOT on Colorado’s Restricted Firearms List