Colorado: Statute of Limitations on Debt Collection

Requirements one by one

Governing law

Colorado's contract-debt deadlines split across two statutes in Title 13,
Article 80 ("Limitations - Personal Actions"): § 13-80-101(1)(a), the general
3-year period for "all contract actions," and § 13-80-103.5(1)(a), a separate
6-year period specifically for actions "to recover a liquidated debt or an
unliquidated, determinable amount of money due," plus actions to enforce an
instrument securing or evidencing a debt. Section 13-80-101(1)(a) explicitly
defers to § 13-80-103.5 ("except as otherwise provided in section
13-80-103.5"), meaning the 6-year liquidated-debt statute controls whenever
it applies. Two accrual rules (§ 13-80-108(4) and (6)) and two revival
statutes (§§ 13-80-113, 13-80-115) round out the scheme.

How long you have on a written debt

It depends on whether the amount is liquidated, not on whether there's a
signed writing. A sum is generally "liquidated" if the contract states the
amount owed, or if it can be worked out with a simple computation from
outside evidence, the Colorado Supreme Court has held even an itemized
medical bill without a signed written agreement setting the total counts as
liquidated (Portercare Adventist Health Sys. v. Lego, 2012). Most written
consumer and commercial debt, credit cards, promissory notes, signed loan
agreements, itemized invoices, falls into this liquidated bucket and gets
6 years under § 13-80-103.5(1)(a). A written contract claim seeking a
genuinely unliquidated, undetermined amount instead falls back to the
general 3-year period under § 13-80-101(1)(a).

How long you have on an oral or unwritten debt

The same liquidated/unliquidated line applies regardless of whether there's
a writing at all. An oral debt for a fixed, ascertainable amount is just as
"liquidated" as a written one and gets the same 6 years under
§ 13-80-103.5(1)(a). Only a genuinely unliquidated oral contract claim drops
to the general 3-year period. In practice this means Colorado's real
written-vs-oral gap is much narrower than in states like California, what actually shortens the clock here is an undetermined dollar amount, not
the absence of a signature.

When the clock starts

For an ordinary debt, obligation, or money owed, § 13-80-108(4) sets a
specific rule: the claim "shall be considered to accrue on the date such
debt, obligation, money owed, or performance becomes due", not a discovery
rule. This is distinct from § 13-80-108(6), which sets a discovery-based
accrual ("on the date the breach is discovered or should have been
discovered") for a cause of action framed as breach of an express or implied
contract, agreement, warranty, or trust. The Colorado Supreme Court
confirmed in 2024 that these are genuinely different accrual tests keyed to
how the claim is framed, not interchangeable labels for the same rule
(City & Cty. of Denver v. Bd. of Cty. Comm'rs of Adams Cty., 2024 CO 5).
For an installment debt like a loan, Colorado courts have held a single
missed payment doesn't itself start the clock on the whole balance; the debt
"becomes due" in full only once the creditor takes a clear, unequivocal step
to accelerate it, such as a written acceleration notice or a repossession
with notice of intent to sell (Hassler v. Account Brokers of Larimer
County, Inc., 274 P.3d 547 (Colo. 2012)).

Can a payment or promise restart the clock?

Yes, in two independent ways. Section 13-80-113 requires a signed writing
for a general acknowledgment or promise: "No acknowledgment or promise shall
be evidence of a new or continuing contract sufficient to take a case out of
the operation of the statute of limitations, unless it is in writing signed
by the party to be charged." That same section immediately preserves a
separate route: "this section shall not alter the effect of a payment of
principal or interest." Section 13-80-115 spells out what that means, a
payment stops the clock on its own, without a writing, though a bare
bookkeeping notation by the creditor alone isn't enough proof that a payment
actually happened. Colorado case law treats a voluntary payment as amounting
to "an acknowledgment from which new promise is implied" (Sears v.
Hicklin, 1893). Colorado goes further than several other states on the
signed-writing route too: an express new promise to pay can revive a debt
that has already gone time-barred, not just extend one still running, "[t]o remove the bar of the statute of limitations so that a debt otherwise
barred may be recovered upon a new promise, there must be an express promise
to pay it" (Thomas v. Carey, 26 Colo. 485 (1899)).

Is there a special rule for consumer debt?

Not one that shortens (or lengthens) a creditor's deadline to sue. Claims
under the Uniform Consumer Credit Code get the same 3-year default under
§ 13-80-101(1)(g) as ordinary contract actions, with one internal exception
(§ 5-5-201(5)) that governs a consumer's own claim against a creditor for
a UCCC violation, a different cause of action, not the creditor's deadline
to collect the debt. In practice, most actual consumer debt (credit cards,
personal loans) already qualifies as "liquidated" and gets the longer 6-year
period under § 13-80-103.5(1)(a) regardless of the UCCC cross-reference.

What if the debt originated in another state?

Colorado's version is narrower than a typical stand-alone borrowing statute:
it's a single paragraph, § 13-80-101(1)(k), embedded directly inside the
list of 3-year actions, covering "[a]ll actions accruing outside this state
if the limitation of actions of the place where the cause of action accrued
is greater than that of this state", meaning a longer foreign period gets
capped down to Colorado's own (shorter) period. This session's research did
not find, and Colorado's own § 13-80-103.5 does not contain, a parallel
foreign-accrual clause for the separate 6-year liquidated-debt statute that
covers most actual debt collection, so whether § 13-80-101(1)(k)'s cap
also reaches a liquidated-debt claim, or applies only to the 3-year general
contract actions it's textually housed in, isn't resolved by the statutes'
own text, and no case law construing that specific question turned up this
session.

What actually happens once the deadline passes?

The ordinary default, not an enhanced bar. Colorado case law states plainly
that the statute of limitations "is a bar to the remedy and not to the
right," and that its running "does not extinguish the debt" (Estate of
Ramsey v. State, Dept. of Rev., 42 Colo. App. 163 (1979)). The debt itself
survives; what's lost is the ability to force payment through a lawsuit
unless the debtor fails to raise the expired deadline as a defense.

What trips people up

Because Colorado's real dividing line is liquidated-vs-unliquidated rather
than written-vs-oral, assuming an unsigned or informal debt automatically
gets a shorter deadline is a mistake here, a fixed-amount oral debt gets
the same 6 years as a signed note. The revival rules are also easy to get
backwards: an unsigned but genuine payment can restart the clock on its own,
while a signed acknowledgment that doesn't amount to an express promise to
pay a specific, subsisting debt won't. And Colorado's permissive
revival-of-an-already-barred-debt rule (via an express new promise) is a
real trap for someone who thinks a debt is safely dead and then puts
something in writing that amounts to a fresh promise to pay it.

Common questions

Does the 6-year period apply to my credit card debt?
Almost always yes. A credit card balance is a "liquidated debt", the
amount owed is fixed or readily computable, so it falls under
§ 13-80-103.5(1)(a)'s 6-year period rather than the general 3-year contract
statute.

I made a small payment on an old debt, did that restart the clock?
Very likely, if the payment was voluntary and can be proven. Colorado law
preserves a payment's own effect on the clock separately from the
signed-writing requirement for a general acknowledgment.

Can a debt collector still sue me after the statute of limitations runs?
As a practical matter, only if you fail to raise the expired deadline as a
defense, Colorado treats expiration as barring the remedy, not as an
independent statutory bar on filing or threatening suit the way some other
states do.

Does the debt just disappear once the time limit passes?
No. Colorado case law is explicit that the statute of limitations doesn't
extinguish the underlying debt, only a creditor's ability to force payment
through a lawsuit.

Statutes and sources

• Colo. Rev. Stat. § 13-80-101(1)(a), "All contract actions, including
  personal contracts and actions under the 'Uniform Commercial Code',
  except as otherwise provided in section 13-80-103.5" get 3 years., https://law.justia.com/codes/colorado/title-13/limitation-of-actions/article-80/section-13-80-101/
  (accessed 2026-07-09)
• Colo. Rev. Stat. § 13-80-101(1)(k), "All actions accruing outside this
  state if the limitation of actions of the place where the cause of action
  accrued is greater than that of this state.", https://law.justia.com/codes/colorado/title-13/limitation-of-actions/article-80/section-13-80-101/
  (accessed 2026-07-09)
• Colo. Rev. Stat. § 13-80-103.5(1)(a), "All actions to recover a
  liquidated debt or an unliquidated, determinable amount of money due to
  the person bringing the action ... shall be commenced within six years
  after the cause of action accrues.", https://law.justia.com/codes/colorado/title-13/limitation-of-actions/article-80/section-13-80-103-5/
  (accessed 2026-07-09)
• Colo. Rev. Stat. § 13-80-108(4), "A cause of action for debt,
  obligation, money owed, or performance shall be considered to accrue on
  the date such debt, obligation, money owed, or performance becomes due.", https://law.justia.com/codes/colorado/title-13/limitation-of-actions/article-80/section-13-80-108/
  (accessed 2026-07-09)
• Colo. Rev. Stat. § 13-80-108(6), "A cause of action for breach of any
  express or implied contract, agreement, warranty, or trust shall be
  considered to accrue on the date the breach is discovered or should have
  been discovered by the exercise of reasonable diligence.", https://law.justia.com/codes/colorado/title-13/limitation-of-actions/article-80/section-13-80-108/
  (accessed 2026-07-09)
• Colo. Rev. Stat. § 13-80-113, "No acknowledgment or promise shall be
  evidence of a new or continuing contract ... unless it is in writing
  signed by the party to be charged; but this section shall not alter the
  effect of a payment of principal or interest.", https://law.justia.com/codes/colorado/2021/title-13/article-80/section-13-80-113/
  (accessed 2026-07-09)
• Colo. Rev. Stat. § 13-80-115, "Nothing in this article shall alter,
  take away, or lessen the effect of a payment of any principal or interest
  made by any person ...", https://law.justia.com/codes/colorado/2021/title-13/article-80/section-13-80-115/
  (accessed 2026-07-09)
• Thomas v. Carey, 26 Colo. 485, 58 P. 1093 (1899), an express new
  promise to pay can remove the bar of the statute even for an
  already-barred debt.
• Sears v. Hicklin, 3 Colo. App. 331, 33 P. 137 (1893), a voluntary
  partial payment amounts to an acknowledgment from which a new promise to
  pay the remainder is implied.
• Estate of Ramsey v. State, Dept. of Rev., 42 Colo. App. 163, 591 P.2d
  591 (1979), the statute of limitations bars the remedy, not the
  underlying right; it does not extinguish the debt.
• Portercare Adventist Health Sys. v. Lego, 286 P.3d 525 (Colo. 2012), an itemized medical bill can be a "liquidated debt" even without a signed
  written agreement stating the total.
• Hassler v. Account Brokers of Larimer County, Inc., 274 P.3d 547 (Colo.
  2012), an installment debt "becomes due" in full, for accrual purposes,
  only once the creditor takes a clear, unequivocal act to accelerate it.
• City & Cty. of Denver v. Bd. of Cty. Comm'rs of Adams Cty., 2024 CO 5, confirms § 13-80-108(6)'s discovery-based accrual for breach-of-contract
  claims is distinct from § 13-80-108(4)'s "becomes due" rule for debt
  claims.