1.2 Senate Bill 25-165, Apprentice Supervision & Colorado Board Rules

1.2 Senate Bill 25-165, Apprentice Supervision & Colorado Board Rules

Exam Fast Fact: Colorado has one apprentice supervision limit and it applies everywhere. Under C.R.S. 12-115-115(1), "a licensed electrician shall not directly supervise more than three apprentices at a job site." There is no separate commercial ratio and no separate residential ratio. Two licensed electricians on a job site may directly supervise up to six apprentices; three may supervise up to nine. Remote supervision by phone, radio, or video does not count at all.

Colorado enforces electrical safety at the jobsite, not just in the code book. Two rules do most of the work: a hard numerical cap on how many apprentices one licensed electrician may supervise, and a strict statutory definition of what "supervision" means.

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Senate Bill 25-165: What the 2025 Act Actually Did

Senate Bill 25-165, "Licensure of Electricians," was signed by the Governor on June 3, 2025 and took effect August 6, 2025. It is an amendment to the Electricians Practice Act — not a sunset continuation bill — and it did not change Colorado's supervision limit. Its substantive changes:

Trap to avoid: SB 25-165 is frequently described online as a sunset review that "reauthorized the Board through 2034" and "imposed a 1:1 commercial supervision ratio." Neither claim is in the act. The Board's continuation is handled separately under the sunset provisions at C.R.S. 12-115-105, and the supervision limit in 12-115-115(1) was unchanged by SB 25-165.

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The Supervision Limit: One Licensed Electrician to Three Apprentices

C.R.S. 12-115-115(1) contains two independent requirements:

1. A person may work as an apprentice, but shall not do any electrical wiring for the installation of electrical apparatus or equipment for light, heat, or power except under the direct supervision of a licensed electrician.
2. A licensed electrician shall not directly supervise more than three apprentices at a job site.

              SUPERVISION MATH (C.R.S. 12-115-115(1))
  +----------------------------+--------------------------------+
  | Licensed electricians      | Maximum registered apprentices |
  | directly supervising       | performing electrical wiring   |
  +----------------------------+--------------------------------+
  | 1                          | 3                              |
  | 2                          | 6                              |
  | 3                          | 9                              |
  +----------------------------+--------------------------------+
  Same limit for residential, commercial, industrial, and
  multifamily work. The occupancy class does not change it.

The Board's own fine schedule confirms the number. It lists the violation as "Failure of an electrical contractor to maintain a supervisory ratio of one licensed electrician to three apprentices," citing 12-115-115(1), at $375 for a first offense, $600 for a second, and up to $2,000 per day for subsequent offenses. A separate line item penalizes "Failure of a licensed electrician to supervise an apprentice" at the same $375 / $600 / up to $2,000-per-day levels.

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The Legal Standard of "Direct Supervision"

Colorado does not leave supervision to interpretation. C.R.S. 12-115-103(2.5) defines it in a single sentence:

"Direct supervision" means that the supervising licensed master electrician, journeyman electrician, residential wireman, or photovoltaic installer is physically present at the same physical address where the apprentice is working.

Three consequences follow directly from the words "physically present at the same physical address":

Responsibility flows upward. Under 12-115-115(2), the electrical contractor, journeyman, master, or residential wireman who employs or directly supervises the apprentice is responsible for the work the apprentice performs, and the Board may discipline that licensee under 12-115-122 for the apprentice's improper work. The apprentice's registration is separately subject to discipline.

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Apprentice Registration, Records, and Annual Reporting

Apprentice registration is an administrative obligation on the employer, not only on the apprentice.

1. Registration Within Thirty Days of Hire

C.R.S. 12-115-115(3)(a) requires the electrical contractor to register the apprentice with the Board within thirty days after initial employment. The employer must also remove an apprentice who is no longer employed from the apprenticeship program and notify the Board annually of the termination. Board rules require that experience verification forms be provided within 30 days after an employee leaves.

2. Contemporaneous Hour Records by Category

Board Rule 1.7 requires experience to be documented on the Board's Affidavit of Experience, broken out by work performed in commercial, residential, industrial, and maintenance/service categories and reported in increments of hours and months, signed by the master electrician for, or a signatory authority of, the electrical contractor or employer. Applicants may not verify their own experience.

3. Annual Reporting to the Board (New Under SB 25-165)

By January 1 each year, an electrical contractor, a United States Department of Labor registered apprenticeship program, or a recognized state apprenticeship agency that employs an apprentice in Colorado must report to the Board each apprentice's name, contact information, and cumulative practical training hours and certified classroom hours completed toward the journeyman requirements in 12-115-110. The Board keeps that information confidential except to the apprentice through the apprentice's own registration account.

4. Photovoltaic Experience Credit

Only certain direct-current-side photovoltaic tasks count toward electrical experience. Board rules credit qualifying photovoltaic work at two hours of PV work per one hour of electrical experience, capped at 2,000 hours. Alternating-current-side connections must be performed under proper electrical contractor registration.

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State Licensing Authority and Home Rule Municipalities

Colorado is a home rule state under Article XX of the Colorado Constitution, and cities such as Denver, Colorado Springs, Aurora, Fort Collins, and Boulder operate their own building departments. The boundaries between state and local authority are well settled:

   +-------------------------------------------------------------+
   | 1. STATE LICENSING AUTHORITY (C.R.S. Title 12, Article 115) |
   |    - Trade licensing and examination are statewide.          |
   |    - Local governments do not license electricians or set    |
   |      apprentice supervision limits.                          |
   +-------------------------------------------------------------+
   | 2. MINIMUM CODE FLOOR (Board Rule 1.5 / 3 CCR 710-1)         |
   |    - The Board-incorporated NEC edition is the statewide     |
   |      minimum installation standard.                          |
   |    - Local amendments may be more restrictive, not less.     |
   +-------------------------------------------------------------+
   | 3. LOCAL ADMINISTRATIVE AUTHORITY                            |
   |    - Local permits, fees, and inspections.                   |
   |    - Local business licensing and contractor registration.   |
   +-------------------------------------------------------------+

The general assembly has declared it a matter of statewide concern that people performing electrical work have the necessary skills, and it expressly identified Board enforcement of the licensing requirements and of "the limits on the number of apprentices a licensed electrician is permitted to supervise specified in section 12-115-115(1)" as essential to public safety (C.R.S. 12-115-119(3)(a)). The Board directs its compliance staff to run compliance checks on projects statewide — regardless of whether the permit was issued by the Board, a town, a city, a county, or a state institution of higher education — verifying both licensure and the supervisor-to-apprentice ratio.

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Board Rules and Colorado Code Amendments (3 CCR 710-1)

The Board's rules supplement the National Electrical Code rather than replacing it:

• Rule 1.5, Incorporation by Reference. The Board incorporates NFPA 70, the National Electrical Code, 2026 Edition, as the statewide minimum installation standard, effective August 1, 2026. The rule expressly excludes later amendments or editions, so the adopted edition changes only by rulemaking.
• Equipment approval. Under Board Rule 1.9(B), the Board accepts conductors and equipment tested and listed by a recognized testing agency such as UL, or field-evaluated by a certified Field Evaluation Body under NFPA 790 and 791 with accreditation from the International Accreditation Service or equivalent. Inspectors retain the right to reject equipment they judge unsafe.
• Electric-ready and solar-ready requirements. Under HB 23-1233 and C.R.S. 12-115-107(3)(a), the Board requires permit applicants to comply with the electric vehicle power transfer infrastructure requirements for multifamily buildings in the Model Electric Ready and Solar Ready Code.
• Continuing education. Active licensees complete 24 hours of continuing education each three-year renewal period, including at least 4 hours on NEC changes, with no more than 4 hours credited to safety training. Online courses must be interactive and delivered by an approved Attesting Provider.