Colorado at a glance
- License
- Leasing for others is brokerage; a Commission position says short-term rentals are not brokerage services
- Trust account
- Brokers put short-term guest deposits in a “trust” or “escrow” account; property management money within 5 business days
- Records kept
- 4 years
- Reconciliation
- Monthly three-way (brokerage); monthly two-way for non-brokerage guest deposits
Details and citations for each point are below.
Who needs a license
- A real estate broker includes anyone who, for compensation, rents or leases real estate for another, and engaging in that business without a Commission license is unlawful.C.R.S. §§ 12-10-201, -202, -217
- The statute’s exclusions include an owner (or a 20%+ partner or LLC manager) acting for their own property, an attorney-in-fact acting without compensation, and salaried on-site managers for apartment or condominium owners. None is specific to short-term rentals.C.R.S. §§ 12-10-201, -202, -217
Short-term rental rules
- The Commission’s position is that a short-term rental or occupancy is a license to use property and is not considered real estate brokerage services; a stay longer than 30 days is not automatically a lease. This is a Commission position, not a statute or rule.Commission Position CP-12, Short-Term Rentals
- Even so, money belonging to others that a broker accepts for non-brokerage activities — expressly including guest deposits for short-term rentals — must go into the broker’s or brokerage firm’s trust or escrow account.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
- Division guidance for a broker renting their own property says a trust account is “likely not required” when a platform holds and accounts for the funds; direct bookings bring the trust rule back in.Broker-Owned Properties Managed by the Broker (Spring 2023)
The trust account
- Funds of others are kept in an escrow or trustee account at a bank or recognized depository in Colorado, and are not commingled with the broker’s own funds.C.R.S. §§ 12-10-201, -202, -217
- Each account is named with the word “trust” or “escrow” and a label for its purpose (for example “rental escrow” or “security deposit escrow”), in the brokerage firm’s or employing broker’s name.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
- Property managers keep at least one account for rental receipts and at least one for security deposits. Property management money is deposited within five business days of receipt (or of the lease being signed, if later); other money within three.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
- Money in trust that becomes due to the brokerage firm is withdrawn monthly. The firm may deposit its own money to cover bank charges if it is recorded in the journal and ledger; the rule sets no dollar cap.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
- Without a specific written agreement, interest on a trust or escrow account does not belong to the brokerage firm.Broker-Owned Properties Managed by the Broker (Spring 2023)
Advance rents and deposits
- “Money belonging to others” expressly includes guest deposits for short-term rentals, rental receipts and security deposits.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
- Unless agreed otherwise in writing, fees are earned — and available to the firm — only after all contracted services are performed and nothing can be recalled. Money collected before services are performed is held in trust.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
- Security deposits go to the owner only with the tenant’s written authorization or notice, and the rules set disclosure and transfer timing when the manager changes.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
Records and how long to keep them
- Records the Commission’s rules call for are kept for four years and are subject to inspection.C.R.S. §§ 12-10-201, -202, -217; 4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
Reconciliation and ledgers
- Brokerage trust accounts keep a journal and a ledger per beneficiary; no ledger may go negative, and the ledgers must always add up to the journal.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
- A three-way reconciliation is done monthly: the journal balance, the sum of the ledgers and the reconciled bank balance agree on the same date, with a report kept. Written internal accounting controls are required.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
- For short-term guest deposits held for non-brokerage activity, the rule calls for a journal and a monthly two-way reconciliation of journal and bank.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
- Owner statements are due within 30 days after month-end unless the management agreement says otherwise.4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20
Check with the Colorado Real Estate Commission (Division of Real Estate, DORA)
We could not confirm these from a primary source, so we don’t state them as rules:
- Whether someone without a license may manage short-term rentals for others for pay rests on a Commission position (CP-12), not a statutory exemption — confirm with the Commission before relying on it.
- The statute says “in this state” for the depository; the rules’ definition of a recognized depository does not.
- Statute and rule text was read in the Division’s 2026 Colorado Real Estate Manual, not the Secretary of State’s rules site or the statute site.
- Whether Colorado’s landlord-tenant security deposit statute reaches short-term guest deposits was not researched.
Sources
Each source was read on 2026-10-25.
- C.R.S. §§ 12-10-201, -202, -217 — Colorado Division of Real Estate (2026 Real Estate Manual, ch. 1)
- 4 CCR 725-1 Rules 1.35, 5.1–5.20, 6.20 — Colorado Division of Real Estate (2026 Real Estate Manual, ch. 2)
- Commission Position CP-12, Short-Term Rentals — Colorado Real Estate Commission
The reconciliation itself
Whatever your state’s rules, the monthly check is the same idea: the bank, your books and what you hold for each owner and guest should agree. Our three-way reconciliation guide walks through it with a free worksheet. If your reservations run on VacayOps, trust accounting is part of the Full Platform: guest payments are recorded into trust, owner statements build each owner’s balance, and the month’s reconciliation is signed off and exported as a PDF for your accountant. VacayOps records and reconciles the money in your own bank and processor accounts. It never holds or moves funds.