Bulletin 25-03

July 18, 2025

As stated in FDD Bulletin 25-02 and 25-02-C, the Colorado state definition of “Dealer” is tied to the specific type of Federal Firearms License (“FFL”) held by a business or individual. The Colorado definition of “Dealer” also includes FFL holders with a type 09, 10, or 11 license who engage in sales of firearms at retail to the public. See §18-12-401(1), C.R.S.

Holders of license types 09, 10, and 11 are licensed to deal in, import, or manufacture destructive devices or armor piercing ammunition. These FFL types also have the added privilege of dealing in firearms other than destructive devices, including selling firearms other than destructive devices at retail to the public. See 27 CFR 478.41(b).

Subsection 18-12-401.5(1)(d), C.R.S. states that a dealer who only deals in destructive devices is not required to obtain a state permit to engage in the business of dealing in destructive devices. Reading all provisions together, the law requires that any type 09, 10, or 11 FFLs that sell firearms, other than destructive devices, at retail to the public must also obtain a Colorado State Firearms Dealer Permit.

If you hold a type 09, 10, or 11 FFL and sell firearms, other than destructive devices, at retail to the public, please submit your application for a state Firearms Dealer Permit as soon as possible to remain compliant with state law. The Division will expedite the applications of these parties as it is able. If you have any additional questions, please contact the Firearms Dealer Division at DOR_FDD@state.co.us.

If you have questions about your InstaCheck account, please contact the Colorado Bureau of Investigations at (303) 813-5700, Option 5.

Firearms Dealer Division

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