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ABA licensure by state

ABA licensure in Colorado: who needs a license, how to get one and how to keep it

The short answer

Colorado has passed a behavior analyst licensing law, but the license requirement does not start until July 1, 2028. House Bill 26-1425, which the Governor signed on June 2, 2026, creates the Colorado Behavior Analyst Licensing Board under the Division of Professions and Occupations and licenses behavior analysts and assistant behavior analysts. From July 1, 2028, an individual "shall not engage in or offer to provide the practice of applied behavior analysis" without a license, unless an exemption applies. Behavior technicians, including RBTs, are not licensed under the act.

What the law says

Confirm with the Colorado Division of Professions and Occupations before you rely on this.

The law is House Bill 26-1425, Chapter 299 of the 2026 Session Laws of Colorado. It adds Article 247 to Title 12 of the Colorado Revised Statutes, the "Applied Behavior Analysis Practice Act." The act's effective-date section says:

"This act takes effect upon passage; except that sections 12-247-106, 12-247-110, 12-247-112, and 12-247-118, Colorado Revised Statutes, as enacted in section 2 of this act, take effect July 1, 2028."

The licensing duty is in 12-247-106, which starts July 1, 2028:

"Except as otherwise provided in section 12-247-115, an individual shall not engage in or offer to provide the practice of applied behavior analysis unless the individual is licensed under this article 247."

The same section protects the titles:

"An individual shall not designate themselves or hold themself out as a licensed behavior analyst unless the individual is licensed as a licensed behavior analyst under this article 247."

The act defines the practice this way:

""Applied behavior analysis" means the design, implementation, and evaluation of instructional and environmental modifications to produce socially significant improvements in human behavior."

It says applied behavior analysis does not include "diagnosis," "psychological testing," "psychotherapy," "cognitive therapy," "psychoanalysis," "mental health counseling," "practice with nonhumans" or "business or organizational consulting, including organizational behavior management services."

Unlicensed practice is a crime from July 1, 2028. Section 12-247-118 says an individual who "practices or offers or attempts to practice applied behavior analysis without an active license as required by and issued under this article 247 is subject to penalties pursuant to section 12-20-407 (1)(b)." The act adds applied behavior analysis to the list of professions in 12-20-407, where a person who practices without an active license "commits a class 2 misdemeanor."

The exclusions are in 12-247-115. The article "does not prohibit or restrict the practice of" the following, among others:

"A health-care professional licensed, certified, or registered under this title 12 and practicing in this state and any individual practicing under their supervision in accordance with this title 12, if: (I) Applied behavior analysis is within the scope of practice applicable to the individual under this title 12; (II) The applied behavior analysis services provided are within the scope of the licensed health-care professional's education, training, and competence; and (III) The licensed, certified, or registered health-care professional or supervisee does not represent themselves using titles protected under section 12-247-106"

"A caregiver of a recipient of applied behavior analysis services who provides applied behavior analysis services under the authority and direction of a licensed behavior analyst or a licensed assistant behavior analyst."

"A matriculated college or university student or postdoctoral fellow whose applied behavior analysis activities are part of a defined program of study, course, practicum, internship, or fellowship and are directly supervised by a licensed behavior analyst or a qualified faculty member located in this state."

"An individual employed by a school, as defined in section 22-1-132 (2)(c), performing the duties of their position."

A school employee covered by that last exclusion may not "offer applied behavior analysis services to a person other than the students of their school employer" or accept pay for those services other than from the school employer. The same section also covers "unlicensed individuals from pursuing experience in applied behavior analysis consistent with the experience requirements of the board," if supervised as the board requires.

The act says nothing in it "authorizes the board to regulate applied behavior analysis clinics licensed pursuant to sections 26-6-905 and 26-6-909.5." The legislature's official bill summary adds that "The department of human services (department) is required to prescribe and publish standards for the licensing and regulation of applied behavior analysis clinics (clinics)."

The act repeals the licensing article on September 1, 2031, "Before the repeal, this article 247 is scheduled for review in accordance with section 24-34-104."

Source: HB26-1425, Chapter 299, Session Laws of Colorado 2026 (Colorado General Assembly); HB26-1425 bill page and summary.

How to get licensed

The board has five members appointed by the Governor: "Three members who are licensed behavior analysts," "One licensed assistant behavior analyst" and "One public member." The Governor makes the initial appointments "no later than one hundred eighty days after the effective date of this section," and the board "has the following powers and duties," among them to "Adopt, amend, or repeal rules to administer and enforce this article 247" and to "Charge fees pursuant to section 12-20-105." The act authorizes the board to establish application requirements, adopt rules and charge fees. We could not verify current application availability, board rules or fee amounts. The official bill summary confirms that implementation depends on board requirements and rules.

For a behavior analyst license, an applicant under 12-247-107 must submit "a completed application as required by the board" and:

"Have a current, valid certification in good standing with a certifying entity as a certified behavior analyst, certified behavior analyst-doctoral, or qualified behavior analyst or have another certification as determined by the board;"

The applicant must also "complete a fingerprint-based criminal history record check in accordance with section 12-247-109."

The act defines "certifying entity" as "the Behavior Analyst Certification Board, the Qualified Applied Behavior Analysis Credentialing Board, or another national entity identified by the board" whose credentialing programs are accredited by the National Commission for Certifying Agencies or the American National Standards Institute. Under 12-247-109 the applicant pays the cost of the fingerprint-based check. After the applicant meets the requirements, "the board shall issue a license to the applicant; except that the board may deny a license if the applicant has committed an act that would be grounds for disciplinary action under section 12-247-117." For a license by endorsement, the board "shall issue a license by endorsement to an applicant who satisfies the requirements of the occupational credential portability program described in section 12-20-202 (3)." Under 12-247-122, a licensee "shall not practice applied behavior analysis unless the individual is covered by professional liability insurance in an amount determined by the board by rule," with an exception for licensed behavior analysts and licensed assistant behavior analysts acting within their public employment duties who are granted immunity under the Colorado Governmental Immunity Act.

Source: HB26-1425, Chapter 299, Session Laws of Colorado 2026.

Assistants, RBTs and technicians

Colorado licenses assistant behavior analysts. To apply, a person must have "a current, valid certification in good standing with a certifying entity as a certified assistant behavior analyst or qualified autism service practitioner-supervisor or have another certification as determined by the board" and complete the fingerprint-based check (12-247-108). Under 12-247-112, from July 1, 2028, "A licensed assistant behavior analyst shall practice only under the supervision of a licensed behavior analyst."

Behavior technicians are not licensed. The act defines "Behavior technician," "applied behavior analysis technician," "board certified autism technician," and "registered behavior technician" as terms for "an individual who practices under the supervision of a licensed behavior analyst or licensed assistant behavior analyst in accordance with the requirements of a certifying entity," who "does not design assessment or intervention plans or procedures but delivers services as assigned by the supervisor responsible for their work." The article does not "prohibit or restrict the practice of" "A behavior technician from providing applied behavior analysis services under the supervision of a licensed behavior analyst or a licensed assistant behavior analyst." A behavior technician "shall not represent themselves as a licensed behavior analyst and shall use a title that indicates their nonprofessional status, such as 'ABA technician,' 'behavior technician,' or 'tutor.'" The technician "may use the title of a current, valid credential they possess that has been issued by a certifying entity, such as 'registered behavior technician,' if they are performing functions in accordance with the credential."

Source: HB26-1425, Chapter 299, Session Laws of Colorado 2026.

Renewal and state-required training

Under 12-247-110, which takes effect July 1, 2028, licenses "are valid for a period as determined pursuant to section 12-20-202." Before a license expires, the board may renew it if the licensee submits a completed renewal application "as required by the board by rule" and "the board verifies the licensee's certification by a certifying entity." The license has a grace period after expiration "pursuant to section 12-20-202 (1)(e)."

The act's continuing education rule, 12-247-116, reads:

"Individuals licensed pursuant to this article 247 shall maintain their professional credential issued by a certifying entity as described in section 12-247-107 (1)(a) or 12-247-108 (1)(a), as applicable, and shall practice in accordance with the requirements of the credential and in accordance with rules adopted by the board."

We found no continuing education hours or required topics in the act. The act ties renewal to the credential from the certifying entity and leaves further rules to the board. We did not find any board rules.

Source: HB26-1425, Chapter 299, Session Laws of Colorado 2026.

Training the staff you supervise

If you run a program in Colorado and need new technicians or aides trained in the basics, this is what our Intro to ABA Level 1 course covers.

The Intro to ABA Level 1 course teaches methods and techniques of Applied Behavior Analysis (ABA) for parents and caregivers, teachers, paraprofessionals and behavior technicians who work with a child every day. Topics include what autism is, what ABA is, pairing, errorless teaching and prompting, and active student responding. Complete the course and pass its 40-question final exam with a score of at least 80%. Completing this course earns a Special Learning certificate of completion. That certificate is not a continuing education (CE) certificate. It is basic training in ABA methods for daily practice, not a professional credential. It is not the 40-hour training required for the RBT credential. We do not claim Colorado state approval or continuing education credit for this course.

Two ways to start

Last reviewed: October 30, 2026.

See every state's ABA licensure rules