A plain-language overview of roofing-related compliance under the 2025 Colorado Wildfire Resiliency Code

Wildfire resilience is becoming an increasingly important part of building design across Colorado, and now it is officially part of the code.

As of July 1, 2026, enforcement of the 2025 Colorado Wildfire Resiliency Code (CWRC) began for applicable projects in Wildland-Urban Interface (WUI) areas. The new code establishes statewide minimum requirements designed to help buildings better withstand wildfire exposure. For roofing contractors, that means roofing systems, roof details and adjacent exterior components may all play a role in compliance.

Here is a simplified look at what contractors should know before estimating, permitting or starting work.

First, does the code apply to the project?

The CWRC applies to new construction, additions greater than 500 square feet and re-roofing or exterior work affecting 25% or more of a structure.

Before bidding or contracting work, contractors should review the current WUI maps, determine the wildfire hazard classification and confirm requirements with the local Authority Having Jurisdiction, commonly referred to as the AHJ. Hazard classifications are categorized as low, moderate or high.

Local jurisdictions and fire districts may adopt more comprehensive maps or additional requirements. If local requirements are more restrictive than the minimum CWRC provisions, the more restrictive requirement applies. That makes early communication with both the building department and fire district an important first step.

Understanding structure hardening

The CWRC uses structure hardening requirements to reduce wildfire risk. The level of structure hardening depends on the property’s wildfire hazard classification.

• Class 1 Structure Hardening applies to buildings and structures in WUI areas with low fire hazard severity.
• Class 2 Structure Hardening applies to buildings and structures in WUI areas with moderate or high fire hazard severity.

Class 1: Key roofing requirements

For low-hazard WUI areas, Class 1 requirements focus heavily on roofing materials and roof details. Contractors should be prepared for requirements that may include:

• Class A roof coverings or roof assemblies tested in accordance with ASTM E108 or UL 790.
• Additional protection for roof systems with space between the roof covering and roof deck, such as tile or batten systems.
• Valley flashing made from minimum 26-gauge corrosion-resistant metal, installed over a minimum 36-inch-wide underlayment with cap sheet meeting ASTM D3909.
• Gutters and downspouts made from noncombustible material.
• Attic and rafter ventilation openings covered with noncombustible, corrosion-resistant mesh with openings no larger than 1/8 inch.

The key point is that compliance is not limited to the visible roof covering. Details such as valleys, vents, gutters, downspouts and fire stopping can determine whether the system meets the code.

Class 2: What changes in moderate- and high-hazard areas?

Projects in moderate- and high-hazard WUI areas must meet the Class 1 requirements plus additional Class 2 provisions. These requirements move beyond the roof and address other parts of the structure that can affect wildfire performance.

Class 2 provisions may include protections for eaves and soffits, exterior wall assemblies, exterior wall coverings and flashing at ground, decking and roof intersections. The advisory bulletin also notes that combustible sheathing exposed by gaps at exterior walls, posts or columns must be protected with noncombustible materials or ignition-resistant building materials while still allowing for drainage and moisture control.

For roofing contractors, the practical takeaway is simple: re-roofing work may involve components that connect to the roof but are not traditionally considered part of the roof scope. Contractors should identify those areas early and communicate clearly with property owners about potential compliance upgrades.

Roofing work may trigger adjacent exterior requirements

One of the most important parts of the bulletin is the reminder that roofing work may trigger or be affected by adjacent system requirements. In moderate- and high-hazard areas, exterior requirements can include noncombustible siding, ignition-resistant decking, glazing requirements for windows, doors and skylights, noncombustible attached fencing near the structure and defensible space or home-hardening requirements within 5 feet of the structure.

That means a roofing project can become part of a larger compliance conversation. Contractors should help customers understand that code compliance may require attention to the whole exterior system, not just the roof replacement.

Documentation will matter more than ever

The advisory bulletin encourages contractors to maintain documentation supporting code compliance and inspections. Contractors may be asked to provide:

• Product approvals.
• Class A roof assembly documentation, including ASTM E108 or UL 790 testing information when requested.
• Installation specifications.
• Fire-stop documentation where applicable.
• Photo documentation of critical details.
• Manufacturer installation instructions.

Contractors should also verify compliance with the local AHJ when specific UL, ASTM or equivalent testing or listings are required. The Colorado Roofing Association recommends obtaining written confirmation rather than relying only on verbal guidance.

Do not overlook the fire district

The adoption of the CWRC does not eliminate the role of local fire districts. Fire districts may still enforce fire code requirements that exceed local building codes, especially in WUI areas. They may also be involved in review and inspection.

Failing to coordinate early can lead to redesigns, construction delays, failed inspections or removal of non-compliant work. Early coordination helps protect the project timeline and the customer’s investment.

Contract language should reflect code compliance needs

Because CWRC compliance may require additional materials, documentation or adjacent exterior upgrades, contractors should make sure contract language reflects potential code compliance upgrades and clearly outlines responsibility for associated costs.

This is especially important when a project is located in a WUI area or when the local AHJ or fire district has adopted requirements that are more restrictive than the statewide minimums.

The bottom line

The Colorado Wildfire Resiliency Code treats roofing as part of a broader fire-resistant building system. Compliance requires attention to roof coverings, roof assemblies, ventilation, valleys, gutters, eaves, flashing and adjacent exterior components.

For contractors, the best approach is to plan early, verify the hazard classification, coordinate with the local AHJ and fire district, document everything and communicate potential compliance impacts with customers before work begins.

Contractors who understand these requirements now will be better positioned to educate customers, avoid delays and complete projects that meet today’s wildfire resilience expectations.