Colorado’s COMPS Order has three separate overtime triggers and you owe whichever one pays the most — including a consecutive-hours rule that catches shifts crossing midnight. CDO's engine is built to California's standard — the strictest in the country — so in Colorado it runs with headroom: GPS-verified punches, live break and overtime math on Colorado's actual rules, bilingual EN/ES crews, and the minute-level record that decides wage disputes.
Colorado owes overtime at 1.5× after 40 hours in a week, 12 in a day, or 12 consecutive hours, whichever pays most. Employees get a 30-minute meal on shifts over 5 hours and paid 10-minute rests per 4 hours. The minimum wage is $15.16 (Denver $19.29), and no state heat rule covers construction yet.
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 4, 2026 and effective August 12, 2026, reaches other industries only through data collection and a model prevention plan — it creates no employer duty, trigger temperature or penalty for construction, and the state’s model plan is not due until July 1, 2028.
| Rule | Colorado | For contrast: California |
|---|---|---|
| Overtime | 1.5× past 40/week, past 12/day, or past 12 consecutive hours — whichever pays more | Daily past 8, double time past 12, 7th-day rules |
| Meal breaks | 30 min duty-free for shifts over 5 hours | Before end of hour 5; second before hour 10 |
| Rest breaks | 10 min paid per 4 hours | Paid 10 min per 4 hours, duty-free |
| Heat rules | Agriculture only (7 CCR 1103-15); HB26-1272 sets no construction trigger | Cal/OSHA §3395 — shade, water, cool-downs |
| Minimum wage | $15.16 statewide (indexed each January); Denver $19.29 | State rate plus many higher local rates |
Summary as of October 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.
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, does not change that: it directs the state to build a public heat-incident reporting platform by January 15, 2027 and a model prevention plan by July 1, 2028, and allows later rulemaking — but it creates no employer duty, trigger temperature or penalty today.
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 ($19.84 for 2027). 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 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, and HB26-1272 (effective August 12, 2026) adds data collection and a model plan, not a construction standard; any binding rule would come later through rulemaking.
Wherever the rules land on the strictness scale, the constant is the same: disputes are decided by records. CDO's GPS-verified, minute-level, bilingual punch trail — reviewed by AI, with exceptions surfaced for human judgment — is the record that wins them. See why teams pick CDO
Supersedes Order #39. The three overtime triggers — 40 weekly, 12 daily, 12 consecutive — carry forward, paid at whichever is greater.
A framework law: it orders data collection and a model prevention plan for temperature-related illness across industries, without setting employer duties.
The law takes effect. It sets no trigger temperature, rest requirement or other duty for construction employers, so the operative obligations remain the general duty clause.
The state’s public heat-incident reporting platform is due — the next concrete milestone under HB26-1272.
The state’s model prevention plan is due. Binding rules could follow through later rulemaking; until then it is framework and the general duty clause.
Dated items reflect what was publicly on the books or scheduled as of October 3, 2026. Effective dates slip and rules get amended — confirm current status before you rely on any of this.
Overtime: Weekly only — 1.5× past 40 hrs (federal FLSA). Meals: Not required by state law.
See Arizona rules Neighboring stateOvertime: Two-tier: daily 8-hr OT below $18.00/hr; weekly 40 for everyone. Meals: 30 min unpaid for a continuous 8-hour shift.
See Nevada rules California guideDaily overtime, double time and the seventh-day rule — the benchmark the engine is built to.
Read the guide California guideThe fifth-hour meal window, the §226.7 premium, and waivers.
Read the guide CalculatorRun a shift against California overtime and double-time rules.
Open the calculator CalculatorTest a day against the §512 window and the premium it can owe.
Open the calculatorUnder COMPS Order #40, effective February 1, 2026, overtime at 1.5× the regular rate is owed for hours beyond 40 in a workweek, beyond 12 in a workday, or beyond 12 consecutive hours worked. Where more than one trigger applies, the employer owes whichever calculation produces the greater payment. There is no construction-industry exemption from these rules.
It is a trigger that operates independently of calendar days. If an employee works more than 12 consecutive hours, overtime is owed on the excess even if no single workday contained more than 12 hours. A shift running 7 p.m. to 8 a.m. splits across two workdays and would pass a daily-overtime test, but it is 13 consecutive hours and Colorado owes overtime on the thirteenth. Night work and emergency response hit this routinely.
Yes. A 30-minute uninterrupted, duty-free meal period is required for shifts exceeding 5 hours; where the nature of the work makes relieving the employee impractical, an on-duty meal period is permitted but must be fully paid. Rest breaks are 10 paid minutes for every 4 hours worked, positioned near the middle of each work period where practical.
Not yet, and this is widely misstated. Colorado’s existing heat rule at 7 CCR 1103-15 covers agricultural workers only, with an 80°F trigger and a 95°F increased-risk tier. HB26-1272, signed June 4, 2026 and effective August 12, 2026, is framework legislation: it orders a state heat-incident reporting platform by January 15, 2027 and a model prevention plan by July 1, 2028, but creates no employer duty, trigger temperature or penalty for construction. Federal OSHA’s General Duty Clause applies in the meantime.
$15.16 per hour statewide, adjusted annually for inflation each January 1. Denver sets a substantially higher local rate at $19.29. Contractors working jobs inside and outside Denver run two wage floors simultaneously.
CDO is in a pilot with one California roofing contractor. Colorado’s three overtime triggers — weekly, daily and consecutive-hours — all depend on an accurate minute-level punch record, which is what CDO keeps, along with the 5-hour meal and 4-hour rest schedule. Statewide and Denver wage floors are separate rates to configure, and heat-recovery breaks are logged even though Colorado sets no construction trigger.
GPS-verified clock-ins, breaks and overtime computed live, and the exceptions that need a human — shown on a working crew in 20 minutes.
CDO is in a pilot with one California roofing contractor. Software, not legal advice.