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Boulder SmartRegs: the 100-point rental efficiency standard, who is exempt, and hiring for the upgrades

Every licensed rental in Boulder must reach 100 SmartRegs energy points plus 2 water points (or a HERS score of 120 or less) before the City will approve its rental license (City of Boulder, Steps to SmartRegs Compliance, read 23 October 2026). The upgrades that close the gap are mostly furnace, boiler, water heater and insulation work, and Boulder's HVAC and mechanical contractors filed 4,460 permits from October 2023 to September 2026, usually at $10,572.

By Contractor Records · data through October 16, 2026

The rule, from the City's pages

Item What the City says
Who All licensed rental housing; SmartRegs is part of rental license approval (adopted 2010, Ordinance 7726)
Prescriptive Pathway Inspection by a City-certified Class G Rental Energy Efficiency Inspector; 100 energy points + 2 water points; used 98% of the time
Performance Pathway HERS score of 120 or less from a RESNET-accredited rater; usually suits apartment-style buildings
Scope exemptions Buildings verified to meet the energy code (typically a certificate of occupancy after July 2001), manufactured homes, ADUs and attached owner accessory units
Detached accessory units Must pass
Short-term rentals Not covered
Sale Rental licenses do not transfer to a buyer; SmartRegs compliance does
Still failing after every upgrade Apply for Technically Impractical consideration, showing all feasible points were achieved
Renting unlicensed $150–$500 first violation, $300–$750 second, $1,000 third; $250 investigation fee

Sources: SmartRegs, SmartRegs FAQs, Steps to Compliance, read 23 October 2026. The original deadline passed on 31 December 2018, so today this matters most when a house becomes a rental for the first time or a buyer needs a new license: compliance transfers, the license does not.

The 2026 update

The City's 2026 SmartRegs Efficient Heating and Cooling Update is in community engagement with a 2027 completion date. It proposes adding City-recognized measures to the heating, cooling and hot water tables, removing points for appliances that no longer beat today's minimum efficiency, and keeping the 100-point structure. The City's own reason: air-source heat pumps "do not receive points" now. Only properties that have never met SmartRegs would face the new checklist. If you are choosing between a gas furnace and a heat pump for a rental today, ask the inspector how each scores on the current checklist before you sign.

What it means for hiring

  1. Inspect first, then quote. The inspection report says how many points you are short. Hand it to contractors so they quote the measures that close the gap, not a whole-house package.
  2. The inspector is not the contractor. Inspectors are independent contractors certified by the City who set their own rates. You choose and schedule them; inspections cannot happen during construction.
  3. Get invoices that name the measure. The City says contractor invoices should describe the work that improved the score. "HVAC service" will not earn points; "95% AFUE furnace, model ___" can.
  4. Permits. Furnace, boiler and water heater replacements in Boulder need mechanical or plumbing permits; see Boulder HVAC permit and hiring an HVAC contractor in Boulder. Ask for the permit number and keep it with the invoice.

Compare Boulder HVAC and mechanical contractors by permit record →

What Boulder permits show

Measure HVAC & mechanical Water heater
Permits, October 2023 to September 2026 4,460 1,267
Firms 324 125
Usual filed value $10,572 $3,518
Middle half of firms' usual job $7,750 to $15,000 $2,675 to $4,030
Usual days, issue to final 76 137
Finished (a year or more old) 70.2% 50.9%
Busiest / quietest month August / February April / July

HVAC work is concentrated: Save Home Heat Co Inc alone filed 294 permits in the last 12 months, and the five busiest firms held 40.3% of all HVAC permits. The finished share varies widely by firm: among the 55 firms with 10 or more permits, 29 finish under 70%. An open permit on a rental is one more thing to clear when the house sells, so check the firm's finished share on its page. February is the quietest month for HVAC, the easiest time to book work between tenants.

Five-minute check

  1. Confirm the property's license status by messaging Boulder's rental licensing office with the address, as the Steps page suggests.
  2. Ask two contractors for the permit numbers of past Boulder rental jobs, and look them up as in Boulder building permit search.
  3. Compare finished shares on our Boulder HVAC list and water heater list; prices are on Boulder HVAC cost, counts on Boulder permit statistics.

What this does not tell you

Insulation, air sealing and window work that earns points often needs no permit or sits in other categories, so it is not all in our file. We cannot see which permits were for rentals or which earned SmartRegs points.

How we know this

The rules are from the City of Boulder SmartRegs, SmartRegs FAQs, Steps to SmartRegs Compliance and 2026 SmartRegs Efficient Heating and Cooling Update pages, read 23 October 2026. Permit counts are City of Boulder permits on homes in our HVAC and mechanical and water heater categories, October 2023 to September 2026; the finished share uses permits a year or more old.

Numbers come from City of Boulder construction permits, data through October 16, 2026. Nobody paid to be on this page and nobody can.

Questions

  • How many points do I need to pass SmartRegs in Boulder?

    100 energy efficiency points plus 2 water conservation points on the Prescriptive Pathway, which the City says 98% of properties use. A property that scores 80 at inspection needs 20 more points of upgrades before the next inspection.

  • Does my Boulder rental need SmartRegs if it was built recently?

    Probably not. The City exempts buildings verified to meet the energy code, typically those with a certificate of occupancy issued after July 2001, along with manufactured homes and accessory dwelling units or attached owner accessory units. Keep the documentation.

  • Can an energy audit replace a SmartRegs inspection?

    No. The City's FAQ says an energy audit cannot substitute for a SmartRegs inspection. The inspection must be done by a City-certified Class G Rental Energy Efficiency Inspector, or you can use the Performance Pathway with a HERS score of 120 or less from a RESNET-accredited rater.

  • What is the fine for renting without a license in Boulder?

    The City's SmartRegs FAQ lists a civil penalty of $150 to $500 for a first violation, $300 to $750 for a second and $1,000 for a third, plus a $250 investigation fee. A rental license requires SmartRegs compliance unless an exemption applies.

  • Do heat pumps earn SmartRegs points?

    Not under the current checklist. The City's 2026 update project says air-source heat pumps receive no points and proposes adding them as recognized measures, keeping the 100-point structure; it lists a 2027 completion. Properties that already passed will not need to recertify.

Build your own list

Every firm with that kind of permit on record. Pick what you value. The list moves.