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Coloradothe road title

Colorado opens the road to kei trucks on 1 January 2028

Applications for a kei truck's road title open 1 January 2028.

What changes, for whom and when, the mix ups to avoid in the 430 days between now and then, and what to keep on file so you are ready on the first day.

Every line read 28 October 2026, with its source.

Illustration of a sand coloured Daihatsu Hijet truck in a golden meadow below the Cimarron ridge, with aspens on the slope
Illustration made from a real Daihatsu Hijet photo (CC0, TTTNIS, Wikimedia Commons) and a real Ridgway scene.

The news

A legal road class for kei trucks.

Colorado made kei trucks a legal road class. The law is House Bill 25-1281, signed on 9 May 2025. It takes effect on 1 July 2027, and the DMV opens title and registration for kei vehicles for applications from 1 January 2028. From that day a kei truck that is 25 years old can be titled and plated at the county motor vehicle office like any other truck.

Who qualifies25 years old, 1,000 cc or less, 67 by 140 inches

A kei vehicle has an enclosed passenger cab on four or more tires, an engine of 1,000 cc or less or an electric motor of 56,000 watts or less, is 67 inches wide or less and 140 inches long or less, can reach at least 50 mph, and was 25 years old when imported or is 25 years old with a prior US title. Every kei truck imported under the federal 25 year rule meets the age part. Every Suzuki Carry, Daihatsu Hijet, Honda Acty, Subaru Sambar, Mitsubishi Minicab and Mazda Scrum of the 660 cc generations fits the size.

Two datesPlan for 1 January 2028

People see 1 July 2027 in some places and 1 January 2028 in others. Both are real. The act takes effect on 1 July 2027, and section 13 applies it to applications and offences on or after 1 January 2028. Plan for 1 January 2028, the date the DMV gives.

What changes

A kei vehicle becomes a motor vehicle in Colorado law. It can be titled, registered, plated and insured for the road. Today the DMV says it cannot, for any road.

HB25-1281 sections adding C.R.S. 42-1-102(45.3); DMV page

It may drive roads posted at 55 miles per hour or less. It may cross a faster road only at an at-grade intersection. It may never use a limited-access highway such as I-25 or I-70. Breaking this is a class B traffic infraction.

C.R.S. 42-4-109.7(1), added by HB25-1281

It must be able to reach at least 50 miles per hour. A truck governed to 25 mph is not a kei vehicle, it is a different class, covered below.

C.R.S. 42-1-102(45.3), session law chapter 176

In an emissions area it takes a two speed idle test against the standards for its model year, never a dynamometer test. Ouray County and the rest of the Western Slope are outside the emissions program.

C.R.S. 42-4-310(2)(a)(II); 42-4-304(20)

To confirm

Neither the DMV nor the State Patrol may require an extra inspection only because a vehicle is a kei vehicle, or call it not roadworthy because of its design alone.

HB25-1281 as summarised in the legislature fiscal note, 29 July 2025; the act text is in the session law

A licensed dealer sells a kei vehicle at retail under the motor vehicle and powersports dealer statutes. A dealer is not liable for damages only because the vehicle was not built to US federal standards.

HB25-1281 sections 11 and 12

  1. 9 May 2025Governor signs HB25-1281. It passed the House 64 to 0 and the Senate 35 to 0.To confirm

    legislature floor votes, read in a search summary; fiscal note effective date section

  2. 1 July 2027The act takes effect. No referendum petition was found, and none is reported anywhere we read. The fiscal note says the date holds assuming none is filed.To confirm

    session law section 13; fiscal note

  3. 1 January 2028Applications for title and registration, and the new traffic offence, apply from this day. The DMV uses this as its opening date.

    session law section 13; https://dmv.colorado.gov/specialized-unconventional-and-other-vehicles

What people get wrong

Myth and fact.

MythMini trucks are street legal in Colorado now.No. The DMV says kei vehicles are not legal to title or register for on-highway use..

FactNo. The DMV says kei vehicles are not legal to title or register for on-highway use until 1 January 2028. No Colorado road class fits a gasoline kei truck today.

DMV page, read 28 October 2026; C.R.S. 42-1-102(48.6)

MythRegister it as a UTV or OHV now and convert it later.Nothing we read says a county office or Colorado Parks and Wildlife accepts a kei..

FactNothing we read says a county office or Colorado Parks and Wildlife accepts a kei truck as an off-highway vehicle. The statute defines one as a vehicle designed mainly for use off public highways and generally used for recreation, and a kei truck was built as a road truck. CPW lists no kei or mini truck among what it registers. See why we do not recommend it, below.

To confirm

C.R.S. 42-6-102(11.5); 33-14.5-101(3); CPW page

MythYou can drive it on 35 mph roads today.No. Colorado's low speed road class is for electric vehicles, so a gas kei truck does..

FactNo. Colorado's low speed road class is for electric vehicles, so a gas kei truck does not fit it. The 35 mph you see in county ordinances, Montrose County for example, is a limit on registered off-highway vehicles on county roads, and those ordinances do not name kei trucks. From 2028 the limit for a kei vehicle is roads posted 55 or less.

C.R.S. 42-1-102(48.6); Montrose County Ordinance 2018-01; C.R.S. 42-4-109.7

MythA newer truck will be road legal in 2028.No. The road class needs a truck that was 25 years old when imported, or 25 with a..

FactNo. The road class needs a truck that was 25 years old when imported, or 25 with a prior US title. A newer truck imported as off road equipment becomes a kei off-road vehicle, an off-highway class in the title act, and it never gets a road title under this law.

C.R.S. 42-1-102(45.3) and 42-6-102(6.6) in session law chapter 176

MythMy truck is governed to 25 mph, so it will qualify.No, it is the reverse. A kei vehicle must be able to reach at least 50 mph.

FactNo, it is the reverse. A kei vehicle must be able to reach at least 50 mph. A governed truck is a kei off-road vehicle. Do not govern a 25 year road truck, and do not buy a governed truck expecting a plate.

C.R.S. 42-1-102(45.3); 42-6-102(6.6)

MythAn off-highway registration or a title from another state works here.No source we read says so.

FactNo source we read says so. The DMV's date has no exception for a vehicle titled or plated elsewhere. Colorado Parks and Wildlife sells its own OHV permit to nonresidents at $26.25 a year. A title or novel vehicle registration from another state is only paper that can help prove ownership for the 2028 title, and a prior US title is part of the age test.

To confirm

DMV page; CPW page; C.R.S. 42-1-102(45.3)

MythCPW registration is a title.No. Colorado Parks and Wildlife registers off-highway vehicles.

FactNo. Colorado Parks and Wildlife registers off-highway vehicles. The county motor vehicle office titles them. They are two records at two offices. A CPW decal never makes a truck road legal.

DMV page: titles through the county motor vehicle office, registration through CPW

MythA bonded title gets it past the rule.No. A surety bond in lieu of ownership papers fixes missing paperwork.

FactNo. A surety bond in lieu of ownership papers fixes missing paperwork. It does not change what type of vehicle the truck is, so it does not open the road before 2028.

C.R.S. 42-6-115; DMV bonded title process

MythA farm truck can use the road for farm work.Only if the truck counts as an off-highway vehicle, because that law allows..

FactOnly if the truck counts as an off-highway vehicle, because that law allows agricultural use and crossings. No agency has said a kei truck counts. On your own land it needs no plate and no registration.

To confirm

C.R.S. 33-14.5-108; 33-14.5-102(6)(c) and (d); 42-6-103(2)(b)

MythEmissions rules do not apply to old trucks.Age alone does not exempt one.

FactAge alone does not exempt one. Where you register decides. In the Denver metro and North Front Range program area a kei vehicle takes the two speed idle test every two years if it is 1982 or newer. Ouray County and the Western Slope are outside the program.

To confirm

C.R.S. 42-4-304(20); 42-4-310(2)(a)(II)

MythThe inspection is a safety inspection.No. Colorado has no periodic safety inspection.

FactNo. Colorado has no periodic safety inspection. What the county asks for is a VIN verification on form DR 2698, once, before the first Colorado title, done by a Colorado law enforcement officer, a licensed dealer, a licensed emissions station or the county. After the act takes effect nobody may require an extra inspection only because the truck is a kei vehicle.

C.R.S. 42-6-107(1)(b); 1 CCR 204-10 Rule 26; fiscal note

MythThe Japanese frame number will not title because it is not a 17 character VIN.Colorado's statutes treat any identifying number the maker put on the vehicle as its..

FactColorado's statutes treat any identifying number the maker put on the vehicle as its VIN, including under another country's laws. The state assigns its own number only when none is found or one was altered, for $3.50. The DMV has not said how it will handle a frame number in 2028, so ask.

To confirm

C.R.S. 42-5-201(13); 42-12-202; 42-6-137(5)

MythThe two dates mean I have until July 2027 or until January 2028, whichever I like.The act takes effect on 1 July 2027 but nothing can be filed under it until 1 January..

FactThe act takes effect on 1 July 2027 but nothing can be filed under it until 1 January 2028. Treat 1 January 2028 as day one.

session law section 13

The UTV route

Why we don't recommend the UTV route now.

We do not recommend titling or registering a kei truck as a UTV or an off-highway vehicle now. Colorado's road restrictions lift on 1 January 2028, a 25 year truck then titles directly as a road kei vehicle, and the shortcut has risks the wait does not. This is our view and the reasons for it. It is information, not legal advice.

Our reasons6 reasons
  1. The definitions do not fit. Colorado defines an off-highway vehicle as one designed primarily for use off public highways and generally used to carry people for recreation. A kei truck was designed as a road truck. The legislature's staff note says kei vehicles meet the definition under current law, but a staff note is analysis and not the statute, and no DMV or CPW page agrees.
  2. HB25-1281 did not change the OHV definition. The act adds the kei vehicle as a road class and adds the governed kei off-road vehicle to the title act's off-highway definition from 2028. It leaves the definition CPW registers by, and the one county OHV ordinances use, as it was. So a county's OHV route open to registered OHVs does not name a kei truck.
  3. CPW registration is not a title and no one has said CPW will register a kei truck. CPW's page lists dirt bikes, ATVs, side by sides, UTVs, three wheelers and buggies, and plated street legal vehicles for a permit. It lists no kei or mini truck. A CPW decal is not a title and it does not make a truck road legal.
  4. An off-highway title is a record on the truck. Colorado has titled off-highway vehicles since 1 July 2014 and has required a title to sell one since 1 July 2021. Whether an off-highway title carries a remark, whether a road title can replace it in 2028, and whether the county sees an off-highway title as the 'prior US title' for the age test are not answered by any source we found. A record you may need to undo is a risk the wait does not carry.
  5. A 25 year truck does not need the shortcut. From 1 January 2028 it titles directly as a kei vehicle on its federal papers, CBP Form 7501, DOT Form HS-7 under box 1, EPA Form 3520-1 under code E, the export certificate with a translation and the bill of sale, with a VIN verification on DR 2698.
  6. Going the other way is no easier. Once a truck is registered for the road it falls outside CPW's definition of an off-highway vehicle, and it then needs CPW's off-highway use permit to use designated OHV routes. So a road kei truck still gets its trails, and it loses nothing by going to the road class first.
The waitThe wait is 430 days from 28 October 2026.

The wait is 430 days from 28 October 2026. In that time the truck can be bought, imported, owned and worked on private land or a ranch with no plate. The things to do in the meantime are below.

This is our reading of the law as read on 28 October 2026 and not legal advice. Ask the DMV and CPW the questions at the end of this page, or ask an attorney, before you act.

Before 2028

What to do between now and 2028.

You do not have to wait to start. Everything below works today and nothing in it needs a Colorado title.

  1. Pick a truck that is 25 on the day it enters the United States.

    The federal rule counts 25 years from the date of manufacture to the day of entry. Colorado's age test is also 25 when imported. A truck that is 24 on arrival will not qualify for the federal road lane or for the Colorado class.

    49 U.S.C. 30112(b)(9); C.R.S. 42-1-102(45.3)
  2. Check its size and speed against the Colorado definition.

    1,000 cc or less, 67 inches wide or less, 140 inches long or less, an enclosed cab, four or more tires and able to reach 50 mph. Leave the factory top speed alone.

    C.R.S. 42-1-102(45.3)
  3. Buy and import it on the federal 25 year papers.

    File the entry through a customs broker, declare the truck on DOT Form HS-7 under box 1 and on EPA Form 3520-1 under code E, and pay the duty. The DIY import guide walks each step.

  4. Keep every paper, in one folder, forever.

    CBP Form 7501, the stamped HS-7, the stamped 3520-1, the Japanese export certificate with an English translation signed and notarized or signed under penalty of perjury, the bill of lading, the bill of sale, and the proof of the date of manufacture.

    To confirmDMV bulletin BL 17-01; DR 2395 and DR 2698
  5. Write down the frame number and photograph it.

    Photograph the number on the plate and on the frame, and keep the Japanese registration record that shows it. Insurers and the county will both want the same number. It must match on the title and on the policy character for character.

    C.R.S. 10-4-615(2)(b)
  6. Use it on private land, a farm or a ranch.

    No registration, no plate and no state insurance duty off the public road. Moving it between places means a trailer, because the DMV will not register it for the road before 2028.

    C.R.S. 33-14.5-102(6)(c) and (d); 42-6-103(2)(b); DMV page
  7. Weigh it empty on a certified scale and keep the slip.

    The registration fee for a truck of 16,000 pounds or less runs on its empty weight, and the county may ask for the slip.

    To confirmC.R.S. 42-3-306(5)(a); BL 17-01
  8. Line up a VIN verification for the day.

    Form DR 2698, done in Colorado with the truck physically present, by a Colorado law enforcement officer, a licensed dealer, a licensed emissions station or the county.

    C.R.S. 42-6-107(1)(b); 1 CCR 204-10 Rule 26
  9. Pick your county office and your insurer ahead of time.

    Colorado's minimum is $25,000 per person, $50,000 per accident and $15,000 for property damage. Ask the insurer to write the policy on the frame number.

    C.R.S. 10-4-620
  10. Apply from 1 January 2028.

    Apply at your county motor vehicle office on form DR 2395 within 60 days of purchase or 90 days of arrival if the truck is new to Colorado, with the verification, the papers, proof of insurance and identification. If you live in the emissions area, pass the idle test first.

    To confirmC.R.S. 42-3-103(1)(a); 42-4-310(1)(a)(I)
What to expect to payStatutory amounts, to confirm
To confirm

For a truck of 2,000 pounds or less the statutes set about $7.20 for the title, $7.60 by weight, $7 by age, $3 of specific ownership tax, $16 road safety surcharge, up to $13 bridge surcharge and a few small county and state fees, plus 2.9 percent state sales or use tax and local tax. The full list with cites is states/CO.json ownership fees. The DMV has not said which fee schedule a kei vehicle takes.

Every fee with its cite, in Owning one in Colorado

Newer trucks

The newer trucks' class.

To confirm

A newer truck imported as off road equipment, governed to 25 mph with an EPA certified nonroad engine, has no named Colorado class today. From 1 January 2028 it is a kei off-road vehicle. That is an off-highway vehicle in the title act only, titled at the county motor vehicle office, and a powersports vehicle that a licensed powersports dealer sells at retail.

Where it may run, and what stays unsettled3 open questions

Where it may run. Where an off-highway vehicle may. Private land, farms and ranches, public land and trails open to OHVs, roads a state agency designates open, routes a county or town opens by ordinance and crossings. Never a public road otherwise, and never a limited-access highway.

What stays unsettled

  • Whether CPW will register one. The act adds the kei off-road vehicle to the title act's definition only. It does not amend the CPW definition in 33-14.5-101(3), and CPW lists no kei truck.
  • Whether a county or town OHV ordinance reaches one, since most define an OHV by the CPW definition.
  • The fiscal note says a kei off-road vehicle must carry a permanent 25 mph limiter. The definition the act enacts has no limiter. The governor is the federal condition for importing it as off road equipment, not a Colorado one, and the statute governs.

A kei off-road vehicle does not turn into a kei vehicle because it ages. Whether it could title as a road kei vehicle when it reaches 25, and whether its off-highway title counts as a prior US title for the age test, is a question for the DMV and is listed below.

C.R.S. 42-6-102(6.6) and (11.5); 44-20-402(6.5); 33-14.5-101(3)

Ask them yourself

The questions to ask, and who to call.

Worded for a call. Write down the name, the date and the answer. Both offices change what they say, so ask for it in writing where you can.

Colorado Division of Motor Vehicles, Title and Registration, or your county motor vehicle office303-205-56088 questions

Monday to Friday, 8 a.m. to 5 p.m.1351 5th St., Suite 100, Denver, Colorado 80204

  1. What is the kei vehicle document list for 1 January 2028, and will it be published before then? Is EPA Form 3520-1 on it?
  2. Will the county title a kei vehicle on the Japanese frame number as it is printed, or assign a Colorado number, and which form applies, DR 2408 or DR 2709?
  3. Which fee schedule and which specific ownership tax class does a kei vehicle take, the truck schedule or another?
  4. Will a county office title a kei truck as an off-highway vehicle before 2028? If so, what proof of ownership does it need, and does the title carry a remark?
  5. If a truck holds an off-highway title in 2027, can it be retitled as a road kei vehicle in 2028, and does the off-highway title count as the prior US title in the age test?
  6. Does a truck imported as off road equipment and titled as a kei off-road vehicle ever become a kei vehicle when it turns 25?
  7. How will the county order the emissions test and the first registration for a kei vehicle in the program area, and where do the Western Slope counties send an owner who has no test?
  8. Is a truck from another state, titled or registered as a novel vehicle or a gray market vehicle there, accepted at the 2028 title, and does its prior US title count?

Numbers from the DMV's own contact page

Colorado Parks and Wildlife, off-highway vehicle registration800-244-56135 questions
  1. Will CPW register a kei truck, an imported Japanese mini truck, as an off-highway vehicle today? If not, what is the reason, and is it written down?
  2. From 1 January 2028, when a kei truck is registered for the road with plates, does it need only the off-highway use permit at $26.25 to use designated OHV routes?
  3. Will a kei off-road vehicle, the governed newer truck, be registered by CPW from 2028 even though HB25-1281 did not change the CPW definition?
  4. If a truck is registered with CPW now and later titled as a road kei vehicle, what happens to the registration, and does CPW need to be told?
  5. Does a county or town OHV route that opens to registered OHVs open to a kei truck, or only to what CPW registers?

Numbers from CPW's own page

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