Colorado Body Camera Records Law: 2026 Update

Colorado's body camera records law changed on three fronts in 2026, and records units across the state now have to track all three at once. The Colorado Court of Appeals ruled in April that agencies cannot charge fees before releasing body-worn camera (BWC) footage tied to a misconduct complaint. The Colorado Supreme Court is now weighing whether to take up that ruling. And a new law taking effect this month gives families of people killed by police a guaranteed 21-day window to see the footage, whether or not a misconduct complaint was ever filed. None of this replaces the underlying statute, C.R.S. 24-31-902, which still sets the baseline release deadline and blurring rules every agency has been working under since 2020. Together, the pieces form a more demanding, more time-pressured version of the same framework.

This is a Colorado-specific look at where the law stands as of late August 2026. For the broader, multi-state legislative picture, see our companion piece on what changed in body camera public records law nationally in 2026.

The 21-Day Release Deadline Under C.R.S. 24-31-902(2)(a)

Colorado's Law Enforcement Integrity Act, codified at C.R.S. 24-31-902, has governed body camera release since 2020. Subsection (2)(a) requires a local law enforcement agency or the Colorado State Patrol to release "all unedited video and audio recordings of the incident" to the public within 21 days after the agency receives a request, whenever there is a complaint of peace officer misconduct by another officer, a civilian, or a nonprofit organization.

The statute also builds in a narrow exception for active investigations. Footage that would substantially interfere with or jeopardize an ongoing investigation may be withheld past the 21-day mark, but only up to a hard outer limit: the video must still be released no later than 45 days from the date the misconduct allegation was made. An agency cannot simply cite an "open investigation" indefinitely; the 45-day clock runs regardless.

For records staff, that means every misconduct-related request needs two dates logged the moment it comes in: the 21-day statutory deadline and, if an active investigation is invoked as the basis for withholding, the 45-day outer limit that follows it. Treating the 45 days as a soft target rather than a hard ceiling is one of the more common ways agencies end up out of compliance.

What Colorado's Body Camera Records Law Requires Agencies to Blur

Subsection (2)(b) of the same statute lays out what must be obscured before release rather than left visible. The list is specific: nudity, a sexual assault, a medical emergency, private medical information, a mental health crisis, a victim interview, a minor, personal identifying information (other than the name) of anyone who was not arrested, cited, charged, or issued a written warning, significantly explicit and gruesome bodily injury, and the interior of a home or treatment facility.

The statute is also explicit about the method: agencies must blur this content, not cut it out. The law states that this blurring requirement "does not permit the removal of any portion of the video." An agency that deletes or trims a segment instead of obscuring it has not complied with the statute, even if the underlying privacy concern was legitimate. The only path to withholding footage entirely, rather than blurring it, applies in narrow circumstances where blurring would be insufficient to protect the privacy interest at stake, and even then the affected person or their next of kin generally still has a right to view an unblurred copy.

That distinction matters operationally. A redaction workflow built around cutting problematic footage will not satisfy Colorado law. The workflow has to be built around identifying every frame that falls into one of the statute's blurring categories and obscuring it consistently, while leaving the rest of the recording, including the audio and the surrounding context, intact.

SMB Advertising, Inc. v. City of Boulder: Agencies Cannot Charge Fees for This Footage

On April 9, 2026, the Colorado Court of Appeals decided SMB Advertising, Inc. v. City of Boulder, 2026 COA 25. The case arose after a Boulder-based publisher requested body camera footage related to an officer-involved incident, and the city declined to produce it without payment upfront, citing the fee provisions of the Colorado Criminal Justice Records Act (CCJRA), which generally allow agencies to charge for the cost of searching, reviewing, and redacting records.

The Court of Appeals held that the Law Enforcement Integrity Act's release mandate controls over the CCJRA's fee provisions when a misconduct complaint triggers the 21-day deadline. The court's opinion states that the statute "does not allow a law enforcement agency to condition its mandatory obligation to produce requested recordings on the payment of fees." In other words, an agency cannot hold footage hostage to an invoice once the Integrity Act's release trigger applies, even though the CCJRA would otherwise permit cost recovery for the underlying records work.

The City of Boulder filed a petition for certiorari with the Colorado Supreme Court on June 18, 2026, arguing that the ruling would impose significant ongoing costs on agencies statewide. That petition remains pending as of this writing. It is worth being precise about what is and is not before the Colorado Supreme Court: the appeal challenges only the fee-conditioning holding. It does not ask the court to revisit the 21-day release deadline or the blurring requirements in C.R.S. 24-31-902(2), which were not at issue in the case. Even a full reversal on the fee question would leave the underlying release and blurring timeline untouched. Agencies and their counsel should track the certiorari decision, but records units should not treat the fee question as a reason to slow down on the deadline itself, which remains firmly in place regardless of the outcome.

Our earlier guide to building a defensible video redaction fee policy covers how agencies outside the misconduct-complaint trigger, where fee recovery may still be permitted under the CCJRA, can structure charges so they hold up if challenged.

SB26-190: Faster Access for Families After a Use-of-Force Death

Governor Jared Polis signed Senate Bill 26-190 into law on June 3, 2026. The bill amends the Integrity Act to require that video and audio recordings depicting a peace officer's use of force resulting in death be provided to the decedent's immediate family within 21 days of the incident, regardless of whether a complaint of peace officer misconduct has been filed. That is a meaningful expansion: under the prior version of the statute, the 21-day release clock only started once a misconduct complaint existed. SB26-190 removes that precondition for use-of-force deaths specifically, so the family's access right runs on its own timeline rather than waiting on a complaint to be lodged.

The bill also requires the investigating agency to notify the decedent's immediate family within 24 hours after the scene is cleared, including which agencies are involved in the review and the status of the investigation, and it places limits on public statements by officers that could prejudice related proceedings. SB26-190 lacked a safety clause, so under Colorado's constitutional default it took effect 90 days after the legislature adjourned the 2026 session (May 13, 2026), placing its effective date on August 12, 2026.

For records units, SB26-190 means use-of-force fatalities now carry their own tracking lane, separate from the general misconduct-complaint intake process. A death in custody or during an arrest attempt starts a 21-day family-access clock the moment it happens, not the moment a complaint arrives, and that clock needs to be set immediately rather than discovered later when a request comes in.

Practical Guidance for Colorado Records Units

Layering a fee ruling, a pending appeal, and a new family-notification statute on top of the existing 21-day and 45-day deadlines is a lot for any records unit to hold in working memory. A few operational habits make it manageable:

1. Build intake triage around the trigger, not just the request. The moment a request comes in, or an incident occurs that could trigger SB26-190's family-access clock, log which deadline applies: the general 21-day misconduct deadline, the 45-day outer limit for an active investigation, or the 21-day family-access window for a use-of-force death. Each has its own start date and its own consequence for missing it.
2. Batch officer video review where possible. Multi-camera incidents generate footage from every officer on scene. Reviewing and blurring that footage as a single batch, rather than clip by clip as separate requests trickle in, keeps the 21-day and 45-day clocks from running out on pieces of the same incident at different times.
3. Document lawful withholding in real time. If footage is being withheld past 21 days under the active-investigation exception, write down the specific basis at the time the decision is made, not after a records request is challenged. A contemporaneous note showing why the footage would interfere with an ongoing investigation, and the date by which it must be released regardless, is the record an agency will need if the delay is questioned.
4. Do not condition release on payment where the Integrity Act's fee restriction applies. Under SMB Advertising, invoicing a requester before releasing footage tied to a misconduct complaint is not a safe practice while the certiorari petition is pending, since the Court of Appeals decision remains controlling law in Colorado unless and until the Supreme Court says otherwise.
5. Plan for the added workload in 2027 budgets. Colorado municipal budgets are typically drafted between August and October for the following calendar year, which makes this the right window to account for the redaction labor these overlapping deadlines require, whether that means additional staff time, redaction software, or an outsourced vendor for overflow volume.

Outsourced Redaction as a Staffing Option

Agencies weighing how to absorb these deadlines without adding permanent headcount often land on a hybrid approach: handling routine requests in house and sending overflow, multi-camera incidents, or use-of-force fatalities to an outside redaction vendor with capacity to turn footage around inside a 21-day or 45-day window. That approach only works if the vendor's process matches what Colorado law actually requires, blurring rather than cutting, consistent treatment of every camera angle in an incident, and a documented log of what was blurred and why that the agency can point to if a release is ever questioned. Our guide to what courts look for in defensible video redaction goes deeper on building that kind of record.

Conclusion

Colorado's body camera records law did not change its basic structure in 2026: the 21-day deadline, the 45-day outer limit, and the blurring requirements in C.R.S. 24-31-902 are still the foundation. What changed is the margin for error around that foundation. SMB Advertising, Inc. v. City of Boulder closed off fee-conditioning as a way to slow down misconduct-related releases, at least unless the Colorado Supreme Court says otherwise, and SB26-190 opened a new, complaint-independent deadline for families after a use-of-force death. Records units that already track deadlines carefully will find these changes are additions to an existing system rather than a reason to rebuild it. Units that have been informal about deadline tracking or fee practices have less room than they did a year ago.

Focal Forensics helps Colorado law enforcement agencies and records units meet these deadlines with automated detection, frame-by-frame human review, and a documented redaction log built for exactly the kind of scrutiny C.R.S. 24-31-902 invites. Learn more about our video redaction services or reach out to discuss how your agency's current workflow measures up against Colorado's 21-day and 45-day deadlines.

Phone: 303-900-3585 · Email: info@focalforensics.com

Sources

• Colorado Revised Statutes 24-31-902, Law Enforcement Integrity Act, body-worn camera release requirements
• Colorado Court of Appeals: SMB Advertising, Inc. v. City of Boulder, 2026 COA 25 (April 9, 2026), official opinion summary
• Law Week Colorado: Appeals court rules law enforcement can't charge fees for bodycam footage of alleged officer misconduct
• Colorado Freedom of Information Coalition: Boulder asks Colorado Supreme Court to review ruling on police body camera fees
• Colorado Freedom of Information Coalition: Senate bill provides quicker access to bodycam footage for families of people killed by law enforcement
• Colorado General Assembly: SB26-190, Release Info About Peace Officer Use of Force
• Colorado Public Radio: Colorado bill aimed at greater transparency in officer-involved deaths passes legislature