Your SB24-174 Deadline Says December 31. The Calendar Disagrees.

December 31, 2026 is the date every Colorado jurisdiction subject to SB24-174 has circled. Most local governments over 1,000 residents have to conduct and publish a Housing Needs Assessment by then. The date is real and it is firm. The 2026 legislative session came and went without changing it.

Here is the part that catches towns off guard. December 31 is the finish line, not the starting line. Three separate clocks sit in front of it, and each one quietly moves your real deadline earlier. A jurisdiction that treats December as the month to begin is already behind.

This is not a fear pitch. It is a calendar problem, and calendar problems have clean answers if you see them early.

What is actually due on December 31

The statute is specific. By December 31, 2026, a subject local government must conduct and publish a Housing Needs Assessment that conforms to the methodology DOLA developed. Smaller and declining-population jurisdictions have exemptions, and a town that participates in an approved regional assessment may be covered that way. But for most jurisdictions on the list, December 31 means a finished, published document that follows DOLA's rules.

A published document. Not a draft. Not a plan to start one. That distinction is where the three hidden clocks come in.

Clock one: the assessment is not a weekend project

A Housing Needs Assessment is a real piece of analytical work. It pulls population and household data, projects future need by household size and income, examines the existing housing stock, and addresses displacement risk, among other required elements. Done properly, this generally takes weeks, and for some jurisdictions it can stretch into months depending on data access and staff capacity.

That means the question is not "when is it due." The question is "how long does ours take, and have we started." A town that learns in October that its assessment needs eight weeks of work has run out of room before it began.

Clock two: the back-end process runs into next year

Publishing the assessment is not the last step. After a local government conducts its assessment, the statute requires the governing body to consider it at a public meeting. Within 60 days of that meeting, the local government submits the assessment to DOLA. DOLA then reviews it and makes its determination within 90 days of submission.

Add those up. A jurisdiction that publishes at the buzzer on December 31 still has a public meeting, a submission window of up to 60 days, and a DOLA review of up to 90 days ahead of it. That review process lands well into 2027.

For meeting the publish deadline, that is fine. The risk is different. If the published assessment has gaps, there is no room to fix them before December 31 and resubmit. You cannot revise your way out of a problem you discover in January. The time to find the gaps is before you publish, not after.

Clock three: the money closes in August

If your jurisdiction plans to use grant funding to pay for the assessment, you have a tighter deadline than December. DOLA's Housing Planning Grant Program, which funds exactly this work, runs its next cycle this summer. Round 5 is open from July 13 to August 17, 2026.

Grant funds can support a new assessment or the revision of an existing one to meet SB24-174 requirements, and there is a local match. A town that wants help paying for the work needs to scope its application and apply inside that window. Miss it, and the funding conversation moves to a future cycle while the December deadline keeps approaching.

So the real money deadline for many jurisdictions is not December 31. It is August 17.

The reframe: count backward

Stop reading December 31 as a start date and read it as the latest possible end. Then count backward through the three clocks.

• You want the published assessment in hand by late fall, with margin.
• That means the analytical work starts weeks before, not days.
• If grant funding is part of the plan, the application goes in by August 17.
• And if you want to know whether your current position is close or far from compliant, you want that read now, while there is still time to act on it.

Counted that way, the planning horizon is not the fourth quarter. It is this summer.

Where to start

The first useful move is not to begin building blind. It is to find out where your jurisdiction actually stands against DOLA's methodology, so you know which clock you are really racing.

That is what the SB24-174 Pathway Review does. We apply DOLA's published methodology to your jurisdiction and tell you what you have, what is missing, and what to fix first. For a town with a small gap, that may mean a manageable in-house finish. For a town with a large gap, it means knowing now, in time to start a full build or scope a grant application before the window closes, rather than discovering the gap in October with no runway left.

The deadline is fixed. The amount of time you give yourself is not.

Find out where your jurisdiction stands