By Kim Kichler, Hall Ryan Construction

Colorado’s increasing wildfire risk—driven by climate conditions, population growth in fire-prone areas, and recent catastrophic events—has prompted a major shift in how the state approaches community design and construction. The adoption of the Colorado Wildfire Resiliency Code (CWRC) in 2025 represents one of the most significant policy changes affecting housing in decades. Although the CWRC primarily targets new construction and major renovations, its ripple effects are already being felt in existing HOAs, where governance structures, architectural rules, and shared responsibilities intersect with evolving regulations, insurance expectations, and broader community-wide impacts.This article examines how the CWRC works and, more importantly, how it is likely to impact existing HOA communities across Colorado.

The Policy Framework Behind the CWRC

Created through Senate Bill 23-166, the CWRC establishes statewide minimum standards for wildfire-resistant construction and defensible space in designated wildland–urban interface (WUI) areas. Local governments must adopt regulations meeting or exceeding these standards by July 1, 2026.

The code emphasizes two core strategies:

• Structure hardening (fire-resistant roofs, siding, vents, and windows) 

• Defensible space (vegetation management around structures) 

• Roofing materials and condition 

• Siding and structural components 

• Vegetation proximity and density 

• Slope, access, and defensible space 

• Who pays for vegetation removal in common areas? 

• How are costs shared across homeowners? 

• How are private vs. community responsibilities enforced? 

• Review and update governing documents 

• Revise architectural and landscaping guidelines 

• Implement defensible space standards 

• Plan financially for mitigation efforts 

• Coordinate with local governments and stay informed on WUI mapping 

• Consider following CWRC guidelines for ignition-resistant exterior walls. 

• Stucco and Masonry/Brick: Non-combustible, offering high durability and fire resistance.

• Metal Siding (e.g., Steel): Non-combustible, durable option.

• Fire-Retardant-Treated Wood (FRTW): Specifically treated to meet Class 2 standards.

• Specialized Fiber Cement Brands: Products like Everlast & Hardie Board or other cement boards. 

Although retrofits are not broadly required for existing homes, the CWRC sends a clear signal: properties that do not meet modern wildfire resilience standards represent elevated risk.

Insurance Market Transformation: Rising Premiums and Risk-Based Pricing

One of the most immediate impacts of the CWRC is a sharp increase in insurance premiums across wildfire-prone regions. Insurers now rely on highly granular risk assessments, including:

Properties aligned with CWRC standards tend to receive more favorable pricing, while those that are not face significantly higher premiums. For HOAs with master insurance policies, risk is shared—meaning a single high-risk feature can increase costs for an entire community.

Why Existing HOA Communities Are Uniquely Affected

HOAs play a central role in regulating community design and maintenance through covenants, conditions, and restrictions (CC&Rs). These often govern: exterior materials, landscaping standards, fencing and shared structures and maintenance responsibilities. This means that even when the CWRC does not directly mandate retrofits for existing homes, HOAs become the frontline enforcers—or obstacles—of wildfire mitigation practices.

Key Areas of Impact on HOAs: Conflicts Between Existing Covenants and Fire-Resilient Design

Many HOA rules were created with aesthetic priorities that now conflict with wildfire safety, such as requirements for wood fencing, combustible decking, or dense landscaping. As homeowners seek to upgrade for safety or insurance compliance, HOAs may need to amend governing documents.

Indirect Pressure to Retrofit

Although retrofits are not broadly required, multiple forces are driving “voluntary” upgrades: insurance requirements for defensible space and fire-resistant materials, local regulations tied to permits or inspections and liability concerns for HOA boards. As a result, many HOAs are adopting mitigation standards, requiring inspections, and encouraging upgrades during renovations.

Governance and Cost Allocation Challenges

Wildfire mitigation introduces complex financial questions:

To address these challenges, HOAs may need to increase dues, levy special assessments, or reallocate reserve funds.

Evolving Architectural Review Standards

HOA Board of Directors must shift from purely aesthetic decision-making to incorporating fire risk. This includes approving ignition-resistant materials, revising landscaping guidelines and balancing design preferences with safety.

Financial and Market Implications

The combined effect of CWRC standards and shifting insurance market dynamics is creating tangible financial pressure for HOAs. Associations are facing rising premiums and deductibles, special assessments for mitigation projects, increased dues, and the need to reallocate reserve funds toward wildfire resilience, all of which place new demands on budgeting and long-term financial planning. Insurance availability is also becoming directly tied to property values. Homes that are difficult to insure may face reduced demand and financing challenges, while resilient communities may gain a competitive advantage in the real estate market.

Liability and Governance Considerations

The CWRC establishes a recognized benchmark for wildfire risk management, which may influence how liability is evaluated. HOA boards, property managers, and homeowners could face increased scrutiny if known hazards are not addressed. Maintaining adequate insurance coverage is a core fiduciary responsibility for HOA boards. As insurers impose stricter requirements, associations must demonstrate proactive mitigation efforts to secure and maintain coverage.

The Path Forward

To navigate this evolving landscape, HOA communities and homeowners should:

Suitable alternatives : 

The Colorado Wildfire Resiliency Code is reshaping more than building practices—it is transforming the economics, governance, and risk profile of entire communities. While its direct mandates focus on new construction, its indirect effects are already redefining expectations for existing HOA communities. Insurance markets, responding to escalating wildfire risk, are accelerating this transition—often faster than regulation alone. As a result, wildfire resilience is no longer optional. It has become a prerequisite for insurability, financial stability, and long-term viability in Colorado’s wildfire-prone regions.

The QR code below indicates in red (representing Moderate and High Fire Intensity classifications) on the Colorado Wildfire Resiliency Code (CWRC) map will be enforced to Class 2 structure hardening requirements for new construction and major renovations and additions. 

Scan to see the CWRC map

About the Author: Kim Kichler is a Business Development Representative at Hall Ryan Construction, where she focuses on helping clients navigate construction and restoration solutions. Hall Ryan Construction is a locally and privately owned and operated, Class A licensed general contractor specializing in commercial, HOA, and multi-family construction projects, delivering comprehensive building and restoration services across complex property types.