The Colorado Division of Insurance (DOI) has officially postponed the HB-1182 wildfire risk model rule-making hearing originally scheduled for Monday, December 15th, extending the timeline for final implementation of the statute’s requirements. While a new hearing date has not yet been announced, the postponement does not signal a change in legislative intent, nor does it reduce insurers’ ultimate compliance obligations. For carriers writing property insurance in Colorado, this pause presents a strategic opportunity.
WHAT THE POSTPONEMENT MEANS — AND WHAT IT DOESN’T
HB-1182 remains law. The statute still requires insurers that use wildfire risk models, catastrophe models, or scoring systems to:
- Incorporate property-specific and community-level mitigation factors
• Provide clear explanations of wildfire risk scores to policyholders and applicants
• Offer a defined appeals process for wildfire risk determinations
• Document model inputs, methodologies, and mitigation adjustments for DOI review
• Demonstrate how mitigation actions impact underwriting, pricing, or eligibility
The postponed hearing simply delays the final administrative rules that clarify how these requirements must be operationalized and reported. It does not delay the expectation that carriers will be prepared to comply once rules are finalized.
WHY THIS WINDOW MATTERS FOR CARRIERS
Rulemaking delays are common—especially for legislation as technically complex as HB-1182. What separates prepared carriers from reactive ones is how this time is used.
This interim period allows carriers to:
- Audit existing wildfire risk models and scoring methodologies
• Identify gaps in mitigation factor inclusion and documentation
• Design or refine policyholder score explanation and appeals workflows
• Evaluate third-party partners that can support compliance at scale
• Prepare internal teams for DOI scrutiny during upcoming rate filings
When rulemaking resumes, carriers that wait will be forced into compressed timelines. Carriers that prepare now will move through compliance deliberately and defensibly.
ROMO FIRE’S ROLE DURING THE INTERIM PERIOD
Rocky Mountain Fire Assessment Systems was built specifically to help insurers navigate HB-1182, not just at a policy level, but at an operational one.
Our platform and services are designed to support carriers before, during, and after rule finalization by providing:
- Property-specific wildfire risk assessments aligned with HB-1182 requirements
• Transparent scoring documentation suitable for policyholder disclosure
• Mitigation recognition frameworks that support underwriting and discount strategies
• Appeals support tools to explain and defend individual wildfire risk scores
• Carrier-ready reporting to streamline DOI rate filing and audit readiness
In short: we help carriers move from interpretation to implementation.
A STRATEGIC TIME TO ENGAGE…NOT WAIT
The postponement of the rules hearing gives carriers something rare in regulatory environments: time.
Time to ask hard questions.
Time to pressure-test models.
Time to align compliance, underwriting, actuarial, and customer communications.
ROMO Fire is currently offering HB-1182 compliance readiness consultations to help carriers understand where they stand today and what will be required when rule-making resumes.
NEXT STEPS
If your organization writes property insurance in Colorado and uses any form of wildfire risk scoring or modeling, now is the time to prepare, not react.
Contact ROMO Fire to schedule a confidential HB-1182 compliance discussion and readiness review.
We’ll help you use this pause strategically, so compliance becomes a competitive advantage…not a scramble.
