3Separate overtime triggers — weekly, daily, and consecutive-hoursCOMPS Order #40
12Consecutive hours — a trigger that ignores calendar days7 CCR 1103-1
$15.16State minimum wage — indexed annually each January 1Denver: $19.29
Aug 122026 — heat rules expand beyond agricultureHB26-1272
Colorado in short
Colorado has three overtime triggers, not one. Under COMPS Order #40, effective February 1, 2026, an employer owes 1.5× the regular rate for hours worked beyond 40 in a workweek, 12 in a workday, or 12 consecutive hours — and where more than one applies, you pay whichever produces the greater amount. The consecutive-hours trigger is the one that surprises people: it disregards calendar-day boundaries, so a shift running 7 p.m. to 8 a.m. hits it even though neither calendar day contains 12 hours. There is no construction-industry exemption.
Colorado also mandates breaks: a 30-minute duty-free meal period for shifts over 5 hours, which must be fully paid if the nature of the work makes relief impractical, and a paid 10-minute rest period per 4 hours. On heat, be precise: Colorado’s current rule (7 CCR 1103-15) covers agricultural workers only. HB26-1272, signed June 2026 and effective August 12, 2026, extends coverage to other industries including construction — but it is a framework law with no numeric trigger temperatures set for construction yet, and a model prevention plan not due until July 1, 2028.
Summary as of July 2026 — rules move; verify current requirements with the Colorado labor department and qualified counsel. The California column is there for scale, not because it applies to you: it's the regime CDO's engine was built to, which is why Colorado's rules run inside it with room to spare.
What Colorado employers actually have to get right
Colorado’s overtime rules live in the COMPS Order (7 CCR 1103-1), currently Order #40, effective February 1, 2026. It sets three independent triggers: more than 40 hours in a workweek, more than 12 hours in a workday, or more than 12 consecutive hours worked regardless of when the workday starts and ends. Where more than one applies to the same hours, you owe whichever calculation pays the most. There is no construction-industry exemption.
The consecutive-hours trigger is the one that produces unexpected liability, because it deliberately ignores calendar-day boundaries. A shift that runs 7 p.m. Tuesday to 8 a.m. Wednesday splits across two workdays — neither of which contains 12 hours — but it is 13 consecutive hours, and Colorado owes overtime on the thirteenth. Storm response, emergency repairs, and any night work make this live for contractors.
On breaks, Colorado requires a 30-minute uninterrupted, duty-free meal period for shifts exceeding 5 hours. Where the nature of the work makes relieving the employee impractical, an on-duty meal is permitted but must be fully paid. Rest breaks are 10 paid minutes per 4 hours worked, ideally near the middle of each work period.
Heat is where Colorado is most often described incorrectly, including by vendors. Today, Colorado’s heat rule (7 CCR 1103-15 §3) applies to agricultural workers only — with an 80°F trigger for water, shade, and monitoring, and a 95°F "increased risk" tier requiring rest after a maximum of two hours of work. Construction is not covered by it. HB26-1272, signed June 4, 2026 and effective August 12, 2026, extends heat protections to other industries including construction, but it is a framework: it sets no numeric trigger temperatures for construction, requires a CDLE reporting platform by January 15, 2027, and does not require a model prevention plan until July 1, 2028.
Wages move annually. The state minimum is $15.16 for 2026 and indexed each January 1, while Denver runs a substantially higher local rate at $19.29. Colorado’s paid sick leave under the Healthy Families and Workplaces Act accrues at one hour per 30 hours worked, capped at 48 hours a year, and — unlike Washington’s — is usable immediately with no 90-day waiting period.
The one most Colorado contractors get wrong
The 12-consecutive-hours trigger, because it is not a daily rule in disguise. A shift from 7 p.m. Tuesday to 8 a.m. Wednesday spans two workdays, neither containing 12 hours, so a daily-overtime check passes it cleanly — but it is 13 consecutive hours and Colorado owes overtime on the last one. Storm work, emergency repairs, and night shifts hit this routinely, and most payroll configurations only test the daily and weekly triggers. The second trap is heat: contractors assume Colorado regulates construction heat exposure today. It does not — agriculture only, until August 12, 2026, and even then without numeric triggers for construction until 2027–2028.
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